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International Taxation Arrangements


On 2 May 2002 the Treasurer announced details of a review of international tax arrangements concentrating on at least four principal areas:

The Treasurer announced that the Board of Taxation would be undertaking public consultation on these issues following the public release of a paper prepared by the Treasury.

Consultation Paper

On 22 August 2002 the Treasurer released the consultation paper Review of International Taxation Arrangements, prepared by the Commonwealth Department of the Treasury.

The Chairman of the Board of Taxation welcomed the release of the consultation paper. The Board also announced details of the consultations that it planned to undertake on the paper.

The Board held a consultative seminar in Sydney on the 30 September 2002.

The Board requested written submissions on the Review of International Taxation Arrangements by 31 October 2002. All submissions received were acknowledged.

Board Report and Government Response

On 28 February 2003 the Board provided the report into the Review of International Taxation Arrangements to the Treasurer. The Treasurer released Volume 1 and Volume 2 of the Boards Report on 13 May 2003 (Volume 3 of the report involved confidential submissions which was not released by the Treasurer).

The Treaurer stated in his press release, ‘I would like to thank the Board for this crucial work in reviewing the complex area of international taxation law.

‘The package of reforms announced by the Government will improve the competitiveness of Australian companies with offshore operations. These reforms will reduce the costs of complying with the controlled foreign company (CFC) rules, reduce tax on foreign ‘active’ business income, and effectively reduce foreign taxes by modernising Australia’s tax treaties.

‘The reforms will encourage the establishment in Australia of regional headquarters for foreign groups and improve Australia’s attractiveness as a continuing base for our multinational companies. The reforms will also enhance the competitiveness and reduce the compliance costs of Australian based managed funds.’

Of the Board’s recommendations most were endorsed by Government, with some amendments not adopted or considered unnecessary or deferred (2.1(1), 2.1(1), 3.1(1), 3.1(2), 3.6 and 4.3 and 3.12) and some to be considered as part of the review of the foreign source income anti-deferral rules. Details of this later review can be found here.

For further information on this review please contact the Board of Taxation Secretariat on (02) 6263 4366 or at

Submissions received

AJ Baxter and Associates124KB
Association of Superannuation Funds of Australia243KB
Australian Bankers' Association1MB
Australian Custodial Services Association598KB
Australian Institute of Company Directors264KB
Australian Skandia134KB
Australian Stock Exchange (attachment)1020KB
Australian Stock Exchange (submission)205KB
Barkoczy & De Silva1MB
BHP Billiton360KB
Boyd International310KB
British American Tobacco103KB
Business Coalition for Tax Reform234KB
Business Council of Australia and the Corporate Tax Association (1)863KB
Business Council of Australia and the Corporate Tax Association (2)97KB
Clough Ltd186KB
Corporate Super Association221KB
Council of Small Business Organisations88KB
CPA Australia256KB
Deloitte & Touche LLP - Washington149KB
Deloitte Touche Tohmatsu - Australia692KB
Deloitte Touche Tohmatsu - NZ221KB
Ernst & Young589KB
Export Finance & Insurance Corporation143KB
Fernandez, Prafula1MB
Goodman Fielder120KB
Grant Thornton125KB
Institute of Chartered Accountants Australia (1)365KB
Institute of Chartered Accountants Australia (2)51KB
Institute of Chartered Accountants NZ170KB
Insurance Council of Australia73KB
International Banks and Securities Association of Australia1MB
Investment & Financial Services Association (1)538KB
Investment & Financial Services Association (2)143KB
Joint 10 public companies262KB
Lloyd-Smith, G86KB
Mayo, Wayne327KB
Minerals Council of Australia1MB
National Institute of Accountants87KB
NZ Corporate Taxpayer Group158KB
Property Council of Australia129KB
Rider, Cameron97KB
Rio Tinto212KB
Taxation Institute of Australia387KB
Taylor, John428KB
Victorian Government Deptartment of Innovation220KB
Western Australia Government144KB
Westfield America Trust237KB
Westfield Holdings332KB
Westfield Trust197KB

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