Ryan Leslie

1 month ago | herbertsmithfreehills.com | Toby Eggleston |Ryan Leslie |Jay Prasad |James Pettigrew

Treasury's recent overhaul of the FIRB tax conditions framework represents a fundamental shift in how foreign investment applications will be assessed and conditioned from a tax perspective. The updated Guidance Note 12 eliminates "standard" tax conditions in favour of tailored, transaction-specific conditions will likely require changes to condition precedent drafting in transaction documents.

2 months ago | herbertsmithfreehills.com | Hugh Paynter |Jinny Chaimungkalanont |Toby Eggleston |Ryan Leslie

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Oct 10, 2024 | lsj.com.au | Hugh Paynter |Ryan Leslie |Graeme Cooper |Graeme Cooper -

A A A By , and - Oct 11, 2024 8:00 am AEDT Snapshot The first application by a court of Australia’s enhanced general anti-avoidance rule, the diverted profits tax, has led to more questions than answers and a High Court appeal is likely. The judgment, as it stands, grapples with nascent tax law issues but also broader issues in complex commercial contract analysis. This article analyses the implications of the divided judgment and forecasts the remaining legal questions the High Court may...

Jul 23, 2024 | lexology.com | Graeme Cooper |Hugh Paynter |Ryan Leslie |Geraldine Chan

A majority of the Full Federal Court has upheld an appeal by PepsiCo against the first instance decision which had held it liable to royalty withholding tax and (in the alternative) found it had triggered the diverted profits tax provisions. Given the split in the Full Federal Court, and the disagreement with the judge at first instance, an application for special leave to appeal by the ATO to the High Court seems highly likely, especially on the diverted profits tax issues.

Jul 23, 2024 | lexology.com | Graeme Cooper |Ryan Leslie

The Secretary Senate Economics Legislation Committee Parliament House Canberra Lodged electronically Dear Sir / Ms, Re: Inquiry into Taxation (Multinational—Global and Domestic Minimum Tax) Imposition Bill 2024 and related bills Thank you for your invitation to make a submission to the Committee on the package of Bills intended to enact the 15% global minimum tax in Australian law and introduced into the House of Representatives on 4 July 2024: the Taxation (Multinational – Global and...