International transactions

Failure to report or incorrect reporting of international transactions attract our attention.

In this section

Capital gains withholding
From 1 July 2016, failure to withhold and pay the withholding on the disposal of some types of high-value real property and membership interests can attract our attention

Characterisation of inbound foreign funds
We review cross-border arrangements that mischaracterise inbound foreign funds provided by non-residents to Australian taxpayers when investing in Australian businesses or when repatriating foreign income as gifts or loans from related overseas entities

Foreign residents and taxable Australian property
Foreign residents disposing of taxable Australian property and failing to lodge returns advising of any gain or loss attract our attention

Hybrid mismatch rules
Hybrid mismatch arrangements that enable multinational companies from gaining an unfair competitive advantage by avoiding income tax or getting double tax benefits attract our attention

Intangible assets
We review international arrangements that incorrectly characterise either intangible assets, or activities or conditions connected with intangible assets

International dealings schedule – non-lodgment
We focus on tax returns and other information indicating that cross border transactions have occurred, indicating an international dealings schedule may be required but has not been lodged

Non or under-reporting attributable foreign income
We focus on Australian entities' failure to report or incorrect reporting of attributable foreign income

Non-resident withholding tax – interest, dividend or royalty
We focus on situations where interest, dividend or royalty withholding tax has not been withheld or paid or where it is not declared or reported correctly

Significant global entities
We focus on entities that meet the definition of a significant global entity but don't identify as one on their tax return or fail to lodge documents as required

Country-by-country reporting entities
We focus on entities that fail to declare their country-by-country reporting entity status on their tax returns or lodge documents as required

Residency
We focus on tax residency status changes relating to restructures, asset disposals, or events involving a significant increase in worldwide income

Section 23AH non-assessable non-exempt income
We focus on an Australian company’s overseas branch or permanent establishment income or deductions that have been incorrectly recognised

Thin capitalisation
We focus on Australian and foreign entities that have multinational investments and whose debts exceed 60% of the net value of their Australian investments

Transfer pricing – related party dealings
We focus on income or profits generated in Australia that are not being subjected to domestic tax due to non-arm's length conditions of international related party dealings