Review of Australia’s Foreign Source Income Anti-Tax-Deferral Regime

The Chairman of the Board of Taxation, Mr Dick Warburton, today announced the release of a discussion paper on possible reforms to Australia’s foreign source income anti-tax-deferral regimes (the controlled foreign company rules, the foreign investment fund rules, the transferor trust rules and the deemed present entitlement rules).

The Treasurer announced on 10 October 2006 a review into the rules to be conducted by the Board. The Treasurer asked the Board to identify ways to reduce the complexity and compliance costs associated with these rules, including whether the regimes can be collapsed into a single regime, and to examine whether the regimes strike an appropriate balance between effectively countering tax deferral and unnecessarily inhibiting Australians from competing in the global economy.

To facilitate public consultation, the Board has developed the discussion paper as a basis for further discussion. In developing the paper the Board has conducted some targeted consultations with key stakeholders.

The Board welcomes submissions on the issues raised in the discussion paper. The closing date for submissions is 6 July 2007. Submissions may be sent to:


Fax: (02) 6263 4471


Foreign Source Income
Anti‑Tax‑Deferral Review
Board of Taxation
c/- the Treasury
Langton Crescent

Copies of the Board’s discussion paper are available from Printed versions of the paper are available by email request sent to

To assist in the Review process, the Board is planning to conduct consultation forums in mid‑June 2007. Details of those forums including venues and dates will be released shortly.