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.
assignment (30%) and 2hr exam (70%)
It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. The Completion of LAWS6209 Australian International Taxation will provide students, without such knowledge or work experience, with additional knowledge and skills that will assists in successfully completing this unit.