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dc.contributor.authorHanna, Norman
dc.date.accessioned2020-02-26T05:13:26Z
dc.date.available2020-02-26T05:13:26Z
dc.date.issued2019
dc.identifier.issn0311-094X
dc.identifier.urihttp://hdl.handle.net/10072/391924
dc.description.abstractThis article provides an examination of the Australian income tax implications that may arise if the Commissioner is successful in applying TR 2018/5 such that a foreign incorporated company is considered an Australian tax resident on the basis of central management and control. Many of the foreign incorporated companies caught by TR 2018/5 will also be regarded as resident in their country of incorporation and thus a “dual resident”. Although Australia has a tax treaty network that is available in some cases to potentially resolve the issue of dual residence for treaty purposes, a range of domestic tax law implications will arise when a foreign incorporated company is a dual resident. This article highlights the Australian tax issues faced by a dual resident, including the importance of the relationship between tax treaties and domestic law in addressing these issues.
dc.description.peerreviewedYes
dc.languageEnglish
dc.publisherLawbook Co
dc.publisher.urihttp://sites.thomsonreuters.com.au/journals/category/journals/australian-tax-review/
dc.relation.ispartofpagefrom163
dc.relation.ispartofpageto189
dc.relation.ispartofissue3
dc.relation.ispartofjournalAustralian Tax Review
dc.relation.ispartofvolume48
dc.subject.fieldofresearchAccounting, Auditing and Accountability
dc.subject.fieldofresearchApplied Economics
dc.subject.fieldofresearchLaw
dc.subject.fieldofresearchcode1501
dc.subject.fieldofresearchcode1402
dc.subject.fieldofresearchcode1801
dc.subject.keywordsSocial Sciences
dc.subject.keywordsGovernment & Law
dc.titleThe Application of Australia's Domestic Tax Laws and Tax Treaties Where a Foreign Company is a Resident
dc.typeJournal article
dc.type.descriptionC1 - Articles
dcterms.bibliographicCitationHanna, N, The Application of Australia's Domestic Tax Laws and Tax Treaties Where a Foreign Company is a Resident, Australian Tax Review, 2019, 48 (3), pp. 163-189
dc.date.updated2020-02-26T04:38:59Z
dc.description.versionPublished
gro.rights.copyright© 2019 Thomson Reuters. This article was first published by Thomson Reuters in the Australian Tax Review and should be cited as (2019) 48 AT Rev 1. For all subscription inquiries please phone, from Australia: 1300 304 195, from Overseas: +61 2 8587 7980 or online at legal.thomsonreuters.com.au/search. The official PDF version of this article can also be purchased separately from Thomson Reuters at http://sites.thomsonreuters.com.au/journals/subscribe-or-purchase.
gro.hasfulltextFull Text
gro.griffith.authorHanna, Norman


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