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The Retreating Tax Treaty?
August 21 @ 5:30 PM - 7:30 PM
The Retreating Tax Treaty?
Improper use of tax treaties and source taxation: policy, practice and beyond
Hybrid event
Date: Thursday, 21st August 2025
Time: 5.30pm drinks for 6.00pm start, event concluding at 7.30pm
Location: Level 23, Ernst & Young, 8 Exhibition Street, Melbourne VIC 3000
RSVP: Please register your attendance below. This is a hybrid (online and in-person) event.
About the Seminar
One of the two main subjects for the 2025 Lisbon IFA Congress is “Improper use of tax treaties and source taxation: policy, practice and beyond”. David Watkins (Partner, Deloitte) and Thomas Ickeringill (Partner, EY) are the Australian branch reporters for this topic.
Chaired by Claire Horan (Victorian Bar), this discussion will explore the core focus of David and Thomas’s paper. Their paper deals with the priority and interactions as between double tax treaties and the normal operation of domestic tax laws. In Australia, this intersection has recently become particularly congested as various measures have sought to prevent the so-called “improper use” of tax treaties, preserve and expand taxing rights over Australian sourced income and otherwise give priority to normal domestic tax laws over tax treaties. This session will examine Australia’s tax priorities, the historical relationship between tax treaties and domestic law and the tax measures designed to prevent tax avoidance and protect source-based taxation. This session will also explore recent trends and the current state of play.
Registration
In person
IFA Member Free
Non-IFA Member AUD $75.00
Virtual streaming
IFA Member Free
Non-IFA Member AUD $75.00
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.
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Claire Horan, Victorian Bar (Chair)Claire Horan is one of Australia’s leading junior counsel in taxation matters. Claire acts and advises in a broad range of Federal and State tax disputes, including on transfer pricing, Part IVA, capital/revenue, CGT, R&D, GST, excise, royalties and PRRT issues. She has appeared for both taxpayers and the Commissioner in significant tax cases in the High Court, Federal Court, State Courts and the Administrative Review Tribunal. |
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David Watkins, Deloitte Australia (Speaker)David Watkins is a Partner at Deloitte Australia and has over 30 years’ experience in corporate income tax and international tax covering a wide range of tax issues across various industry sectors. David is the leader of the Deloitte Australia Tax Insights and Policy Group. David has also been involved in various Australian consultation processes involving reforms to Australian tax laws, in relation to BEPS and other international tax matters. David also regularly lectures at the University of Melbourne and the University of Sydney. |
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Thomas Ickeringill, EY Australia. (Speaker)Thomas Ickeringill is Partner at EY Australia in the Tax Controversy & Policy practice. Thomas is a solicitor and accountant specialising primarily in international tax, transfer pricing and anti-avoidance matters. Thomas has experience advising on a wide range of issues, including transfer pricing, treaty interpretation, Part IVA GAAR, DPT, MAAL, withholding tax, thin capitalisation and CGT. Thomas is also the Australian representative of the Young IFA Network. |