Taxation of Offshore Operations (LAWS6129)


This unit examines Australia┬┐s rules for taxing the income earned from offshore operations. The unit examines the taxation of conducting business and holding investments offshore through foreign branches, companies, trusts, partnerships, and hybrid entities. It also examines the repatriation of profits from these entities, the treatment of the cost of financing these operations and the consequences of offshore reorganisations and relocations. The unit examines in detail Australia┬┐s CFC rules, transferor trust regime, the FITO regime, thin capitalisation rules and foreign hybrid rules.

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Further unit of study information


1x2-hr lecture/week


assignment (30%), 2hr exam (70%)

Faculty/department permission required?


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If you are from another Australian tertiary institution you may be permitted to underake cross-institutional study in one or more units of study at the University of Sydney.