International transactions

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

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

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

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

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

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

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

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

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

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

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

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

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

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