Country : Australia
Assignment Task :

Overall objective: You are required to advise a client who is an Australian company seeking to make an investment in a foreign jurisdiction which you select. 

You are required to explain details of your client's business and of the investment proposal. You are free to choose any type of business proposal you like provided that the scenario which you choose raises issues in two or more of the following areas: 

• tax considerations influencing the choice of international business structures 

• financing of the operation 

• utilising tax incentives 

• double taxation relief (i.e. exemptions / foreign tax credits) 

• withholding taxes 

• taxation of business profits / permanent establishment 

• application of double taxation agreements 

• treaty shopping 

• transfer pricing 

• technology / IP transfer 

You are required to advise your client as to the tax effects of the structure that you propose under both Australian law and the law of that jurisdiction. You should also advise how you would recommend structuring the investment so as to achieve the best overall tax result in both Australia and the foreign jurisdiction (taking into account the effect of any relevant anti- avoidance provisions). 

 

Note: Your research into the tax laws of the foreign jurisdiction need not go beyond the information available from such resources as the IBFD databases available via the UNSW Library Website. 

Your structure must involve at least one foreign jurisdiction. 

 

Marks will be awarded for: 

• Commercial reality of the scenario 

• Complexity of issues that your scenario raises 

• Technical accuracy of advice 

• Awareness of relevant cultural and social norms in the host country 

• Written expression / presentation / referencing

 

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  • Posted on : July 20th, 2018
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