Chris Neil

May 29, 2024 | mondaq.com | Adam Woodward |Chris Neil |Tim Frew

The Federal Budget has placed a strong emphasis on increasing support for housing development to address the current housing crisis by introducing over $6.2bn of new and additional spending on social and affordable housing, new housing infrastructure, and rent assistance, amongst others. From a tax perspective, however, the Federal Budget was very light on providing stimulus to increase investment in this area.

Apr 22, 2024 | mondaq.com | Neil Pereira |Tim Edwards |Tim Frew |Chris Neil

The Full Federal Court has dismissed an appeal by Singapore Telecom Australia Investments Pty Ltd (STAI) against transfer pricing assessments issued by the Australian Taxation Office (ATO) in relation to interest deductions claimed on related party debt. By reconstructing the reliable hypothetical transaction to be on independent vendor financing terms, including an implied SingTel parent guarantee, the Court concluded STAI received transfer pricing benefits in the income years under review.

Apr 16, 2024 | mondaq.com | Neil Pereira |Chris Neil |Tim Edwards |Edward Consett

In Minerva Financial Group Pty Ltd v Commissioner of Taxation [2024] FCAFC 281, the Full Federal Court reversed the Federal Court's decision in finding that Australia's general anti-avoidance rules (Part IVA) did not apply to income distributions made by a trust within a stapled group structure. This article analyses the Full Federal Court's reasons for their judgment, highlighting the emphasis placed on the commercial substance over mere tax outcomes obtained.

Mar 26, 2024 | mondaq.com | Neil Pereira |Sean R. Keegan |Andrew Moore |Chris Neil

In this article, we provide an overview of the OECD Pillar 2 framework and the current status of the rules in Australia, and discuss some of the key implications and challenges for Australian taxpayers and tax practitioners. The Organisation for Economic Co-operation and Development (OECD) has developed a two-pillar solution to address the tax challenges arising from the digitalisation and globalisation of the economy.

Mar 26, 2024 | mondaq.com | Neil Pereira |Sean R. Keegan |Andrew Moore |Chris Neil

In this article, we provide an overview of the OECD Pillar 2 framework and the current status of the rules in Australia, and discuss some of the key implications and challenges for Australian taxpayers and tax practitioners. The Organisation for Economic Co-operation and Development (OECD) has developed a two-pillar solution to address the tax challenges arising from the digitalisation and globalisation of the economy.