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Multinational tax integrity – denying deductions for payments relating to intangible assets connected with low corporate tax jurisdictions

This submission is made by the Taxation Committee of the Business Law Section of the Law Council of Australia (the Committee) in response to the exposure draft legislation for the Treasury Laws Amendment (Measures for Consultation) Bill 2023: Deductions for payments relating to intangible assets connected with low corporate tax jurisdictions’ (Exposure Draft) and the Exposure Draft explanatory materials (EM) (together the Measure).

Reference is made to the previous submission of the Law Council dated 9 September 2022 which dealt with the Treasury consultation paper entitled “Government election commitments: Multinational tax integrity and enhanced tax transparency” (Previous Submission).

Legislative references are to the Income Tax Assessment Act 1997 (1997 Act), Income Tax Assessment Act 1936 (1936 Act), and the Taxation Administration Act 1953 (TAA), as appropriate.

Last Updated on 24/05/2023

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