Home       What's New?       Corporate       Business       Published Information       Ministers       Related Websites

Reform of the foreign source income anti-tax-deferral (attribution) rules


Tuesday, 12 May 2009

Content ID:



On 12 May 2009, the Government announced its intention to reform the foreign source income attribution rules. The reforms will better balance the integrity objective of the rules with other objectives such as efficiency, equity, simplicity and low compliance costs. The reforms implement all but one of the Board of Taxation's recommendations that were contained in its report on the review of the foreign source income attribution rules.

The announced reforms maintain the controlled foreign company rules as the primary set of rules designed to counter tax deferral arrangements. Further, the Foreign Investment Fund and deemed present entitlement rules will be repealed.

The Treasury discussion paper outlines the framework for the redesign of the foreign source income attribution rules consistent with the Government’s announcement.

Interested parties are invited to comment on the paper. While submissions may be lodged electronically or by post, electronic lodgement is preferred. For accessibility reasons, please submit responses sent via email in a Word or RTF format. An additional PDF version may also be submitted.

All information (including name and address details) contained in submissions will be made available to the public on the Treasury website unless you indicate that you would like all or part of your submission to remain in confidence. Automatically generated confidentiality statements in emails do not suffice for this purpose. Respondents who would like part of their submission to remain in confidence, should provide this information marked as such in a separate attachment. A request made under the Freedom of Information Act 1982 (Commonwealth) for a submission marked 'confidential' to be made available will be determined in accordance with that Act.

Closing date for submissions: Tuesday, 9 June 2009

Address written submissions to:
Attribution Review Unit
International Tax and Treaties Division
The Treasury
Langton Crescent
Fax: (02) 6263 4352
Email: fsiattribution@treasury.gov.au

For inquiries, please call Haydn Daw (02) 6263 2789

Documents Available:

Acrobat (PDF) documents

 Acrobat (PDF)

Reform of the foreign source Income anti-tax-deferral (attribution) rules   179.57kb

Microsoft Word (RTF) documents

 Microsoft Word (RTF)

Reform of the foreign source Income anti-tax-deferral (attribution) rules   354.40kb

Related Items:

Submissions: Reform of the foreign source income anti-tax-deferral (attribution) rules - 3/07/2009
The abstract for this content item contains formatting that cannot be displayed in this list. Please follow the hyperlink to the item for more detail.

Treasury Portfolio Ministers - Link to website MoreSuper  - Link to website Carbon Price Modelling - Link to Website Clean Energy Future  - Link to website Review of compensation arrangements for consumers of financial services - Consultation Paper  - Link to website