Assignment
INTERNATIONAL TAX PLANNING ASSIGNMENT
You are required to advise a client who is an Australian company seeking to make an investment in a foreign jurisdiction which you select;
You are required to explain details of your client's business and of the investment proposal. You are free to choose any type of business proposal you like provided that the scenario which you choose raises issues in two or more of the following areas:
- tax considerations influencing the choice of international business structures
- financing of the operation
- utilising tax incentives
- treaty shopping
- location of intellectual property and compensation for use of intellectual property
- transfer pricing
- Australian CFC rules
- Repatriation of profits and interaction with Australia's dividend imputation system
If in the opinion of the Lecturer in charge the scenario you create does not raise issues in relation to two or more of the areas in the above list then no marks will be awarded for the assignment.
You are required to state whether your company is widely held or closely held, listed or unlisted, and what the composition of the shareholding in the company is. In particular you are required to state whether or not a majority of shares in the company are owned by Australian resident entities.
You are required to advise the client as to how the investment proposal should be structured so as to achieve the best overall tax result given your company's overall tax objectives and given the wishes of significant shareholders in your company. Your research into the "tax laws of the foreign jurisdiction NEED NOT GO beyond the information contained in the CCH International Tax Planning Manual or country tax summaries contained on the IBFD Tax Research Platform"
Both of these resources are available via the UNSW Library Website or the Moodle site for this course. You are required to indicate to the client the areas in which the client should obtain the advice of a practitioner in the foreign jurisdiction as to the effects of the structure that you propose under the tax and general law of that jurisdiction. Students are discouraged from using material in free on-line sites.
Your structure must involve at least one foreign jurisdiction and may involve more. The jurisdictions may be ones with which Australia has a Double Tax Agreement or may be ones with which Australia does not have a Double Tax Agreement.
Marks will be awarded for the number and complexity of the issues which the scenario you create raises. Marks will also be awarded for the creativity of the solutions with which your proposed structure responds to those issues. Marks will also be awarded for the technical accuracy of the advice which you give. The commercial reality of the scenario which you create and of your proposed structure will also be taken into account in marking the assignment. Marks will also be awarded for your awareness of cultural and social norms in the host country of your investment.
Marks will be awarded as follows:
- Number and complexity of issues that your scenario raises
- Creativity of solutions in response
- Technical accuracy of advice
- Commercial reality of scenario
- Identification of relevant cultural and social norms in the host country and their implications for international business tax planning
LENGTH: 3000 WORDS
MY CONCERNS:
IN ADDITION TO ABOVE MENTIONED HIGHKIGHTED REQUIREMENTS THESE SHOULD BE STRICTLY CONSIDERED
Another thing is GO WITH FOOTER.
- Overall object of is " Australian company engaged in OUTBOUND investment with the motive to increase its overall profits and decrease its tax.
- I suggest not to make the business structure to complex
- stick to may be 3 or a maximum of 4 countries one is Australia, US and rest of 2 can be tax heaven countries which will provide maximum possible tax and profit benefits to the company
- The composition of shareholders is very important to mention and how are they going to be taxed
Interest, with holding taxes on dividends, royalties and interest should be considered in particular
- the sales of the company how is it selling via online, independently or through related entity
- whether they are wholly owned subsidies or partially owned subsidies