Panel Discussion on recent MLI/Double Tax Treaty Developments & Related Issues

With the overlay of the Multilateral Instrument (MLI) on various of Australia’s Double Tax Treaties (commonly from 1 January, 2019), multinational groups should be increasingly aware of the impact of Limitation of Benefits and other key articles in our Double Tax Treaties.

The Seminar/Panel discussion will focus on the following issues;

• the ATO approach to the MLI including the various Synthesised texts released recently for several important Double Tax Treaties including with China, Vietnam, Spain, Thailand, South Africa, Romania, Mexico and most recently PNG;
• priority/topical articles dealing with eg. Limitation of Benefits / treaty shopping / Principal Purpose Test, withholding taxes, Mutual Agreement Procedure, including Arbitration, transparent entities and PE issues;
• recent ATO MLI guidance and developments;
• the proposed extension of the tax penalty regime to large taxpayers that mischaracterise or undervalue interest or dividend payments in the context of withholding tax (per the Mid-Year Economic & Fiscal Outlook);
• recent Australian treaties with Slovenia and Portugal, and other recent related global/US/Indian developments.

Date: Thursday, 20 February, 2025

Time: 5:00pm – 6:30pm (AEST) (followed by canapes)

Location: DLA Piper, Level 22, No. 1 Martin Place, Sydney

RSVP: Please register your attendance below. This is a hybrid (online and in-person) event.

This event is free for members and AUD 75 for non-members. Corporate members can include four attendees free of charge, and additional attendees may participate for free if they are individual members, or AUD 50 otherwise. Please note that membership is free for individuals under 30 and half price for individuals under 40. If you would like to become a member, please do so here.

Hybrid event

Registration form

Speakers

Rhys Manley – Panellist

Rhys Manley is an Assistant Commissioner in the Policy Analysis and Legislation area of the ATO. His portfolio includes the ATO’s contributions to both Pillar 1 and 2, tax transparency including Public CBC, Future Made in Australia Production Tax Credits, the News Media Incentive, Division 855 reform, and other large business and international tax issues. Rhys also holds a PhD in international trade law from Macquarie University.

Graeme Cooper is an Emeritus Professor at the University of Sydney and a consultant to Herbert Smith Freehills. He has worked as a consultant to the ATO, Treasury, Board of Taxation, United Nations, OECD, World Bank, the International Monetary Fund and several foreign governments. He was admitted to legal practice in New South Wales and Victoria, and practised commercial law and tax in Sydney before entering teaching. He has taught in law schools in Australia, Europe and the United States, and holds degrees from the University of Sydney, University of Illinois and Columbia University, New York.

Jock McCormack – Chairman

Member of the Executive Committee (and Treasurer), Australian Branch of IFA, Tax Committee of Infrastructure Partnerships Australia and DLA Piper

Jock McCormack advises a broad range of Australian and foreign based multinational corporations and funds, and is a leading international tax lawyer based in Sydney. He has previous international tax experience based in New York and New Zealand. Jock is an advisor to the Australian Treasury on the Tax Treaties Advisory Panel and the Digital Tax Working Group. He is a graduate of Economics and Law from the University of Sydney and has had guest lecturing roles at the University of Technology, Sydney and New York University.