International transactions

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

Capital gains withholding

Failure to withhold and pay the withholding on disposal of certain high-value real property and membership interests.

Characterisation of inbound foreign funds

Cross-border arrangements that mischaracterise inbound foreign funds provided by non-residents to Australian taxpayers.

Foreign residents and taxable Australian property

Foreign residents disposing of taxable Australian property must lodge returns advising of any gain or loss.

Hybrid mismatch rules

Prevent multinational companies from gaining an unfair advantage by avoiding income tax or getting double tax benefits.

Intangible assets

International arrangements that incorrectly characterise intangible assets, or connected activities or conditions.

International dealings schedule – non-lodgment

How to lodge the international dealings schedule – non-lodgment will attract our attention.

Non or under-reporting attributable foreign income

Australian entities who fail to report or incorrectly report attributable foreign income.

Non-resident withholding tax – interest, dividend or royalty

Where interest, dividend or royalty withholding tax has not been withheld, paid or not declared or reported correctly.

Significant global entities

Entities that meet the definition of a SGE but do not identify as one on their tax return or fail to lodge documents.

Country-by-country reporting entities

Entities that fail to declare their country-by-country reporting entity status on their tax return or lodge documents.

Residency

We review tax residency changes relating to restructures, asset disposals or a significant increase in worldwide income.

Section 23AH non-assessable non-exempt income

We focus on situations where income has been incorrectly recognised as non-assessable non-exempt.

Thin capitalisation
Entities with multinational investments and whose debts exceed 60% of the net value of their Australian investments.

Transfer pricing – related party dealings
Income not subjected to domestic tax due to non-arm's length conditions of international related party dealings.