YIN Event: Global and Domestic Issues in the Taxation of Intangible Assets

Online only event

Tuesday, 12 March 2024

Webinar commences at 6.00pm and concludes at 7.15pm (AEDT).

Register now using the form below

The Young IFA Network is pleased to invite you to the following webinar.

For many years, the taxation of intangible assets has been a source of tension between multinational groups and tax administrations (and, increasingly, between tax administrations). Given the very nature of intangible assets, disagreements often arise in respect of their existence, character, value, location, and the relative importance of the contributions made in different jurisdictions to their value. This gives rise to a wide range of complex and intersecting tax issues and considerations, including transfer pricing, capital gains tax, royalty withholding tax, treaty overlay and anti-avoidance measures.

At a global level, we have seen action taken in the form of a significant rewrite to the Intangibles Chapter (Chapter VI) of the OECD Transfer Pricing Guidelines and the rollout of a treaty-based anti-avoidance rule, in the form of the principal purpose test, in Article 7 of the Multilateral Instrument and Article 29 of the OECD Model Tax Convention. At a domestic level, we have seen the ATO’s recent guidance on intangible assets, including PCG 2024/1 and TR 2024/D1 (superseding TR 2021/D4 and TR 93/12). We have also seen a recent government proposal to deny deductions for payments relating to intangible assets connected with ‘low corporate tax jurisdictions’ (the status of which is to be confirmed).

Please join us to hear about the recent global and domestic developments in this area, including from those directly involved in developing and debating intangibles tax policy and managing intangibles tax issues on a daily basis.

IFA seminars and webinars are free for members and AUD 50 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 Young IFA membership is free for individuals under 30 and half price for individuals under 40. If you would like to join the IFA Australian branch, please do so here.

Panellists

Tim McCarthy

Assistant Commissioner, Australian Taxation Office

Tim McCarthy is an Assistant Commissioner within Public Groups at the ATO. He is currently involved in the ATO’s strategy relating to intangibles and leads a number of income tax and GST engagement and assurance teams. He is the Public Groups Assistant Commissioner with responsibility for PCG 2024/1 and TR 2024/D1.

At the ATO, Tim was previously the International Risk Manager and prior to that was part of the Tax Counsel Network including serving as secretary for the GAAR Panel.

Tim holds a BBA / LLB from Macquarie University.

Julie Abdalla

Senior Counsel – Tax & Legal, The Tax Institute

Julie Abdalla is the Senior Counsel – Tax & Legal at The Tax Institute (TTI). Julie has practised in the corporate tax teams of Big Four and top-tier law firms in London, Sydney and Melbourne. She has expertise in corporate and individual tax matters with a strong international tax focus, including in relation to intangible tax policy.

Julie represents TTI in several external forums including the ATO’s National Tax Liaison Group and the Australian Treasury’s Tax Treaty Advisory Panel, and has appeared as an expert witness in several Senate Committee inquiries. Julie is also a Sessional Lecturer at the University of New South Wales.

Julie has been awarded several scholarships and awards including the International Bar Association Taxes Committee Scholarship, the Australian Lawyers Weekly 30 Under 30 Award in Tax, and a prize from the University of Oxford. Julie holds a BA and a JD from the University of Sydney, and an LLM from the University of Melbourne, part of which was completed at the University of Oxford.

Christian Chan

Senior Associate, Allens

Christian Chan is a Senior Associate in the Tax Practice at Allens where he advises large Australian and international businesses on income tax related investigations and disputes. Christian has a particular expertise in cross-border tax issues, including the characterisation and valuation of intangible assets (eg, product IP or software platforms) and the structures in which they are used.

Christian holds a BSc / LLB from the University of New South Wales.

Registration form

Start by selecting your registration type. Registrations close 11 March 2024.

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