The Resource A critical evaluation of the New Zealand and Australian governments' solution to triangular taxation relief : Part two

A critical evaluation of the New Zealand and Australian governments' solution to triangular taxation relief : Part two

Label
A critical evaluation of the New Zealand and Australian governments' solution to triangular taxation relief : Part two
Title
A critical evaluation of the New Zealand and Australian governments' solution to triangular taxation relief : Part two
Creator
Subject
Language
eng
Summary
In August 2000 the Australian and New Zealand Treasurers announced that they would try and resolve the problem of "triangular taxation". Part two of this article examines the strengths and weaknesses of the pro rata allocation mechanism and contrasts that solution with the streaming alternative. This part of the article also examines a range of debt, equity, and profit repatriation strategies that trans-Tasman countries could implement to solve triangular taxation. These include floating special purpose subsidiaries, the use of hybrid instruments and techniques to minimize Australian capital gains tax. The article concludes that the pro rata allocation model is unlikely to lead to any significant decrease in trans-Tasman tax driven investment
Citation source
In: New Zealand journal of taxation law and policy. - Wellington. - Vol. 9 (2003),
http://library.link/vocab/creatorName
Dunbar, D.G
Geographic coverage
Pacific Islands
Language note
English
http://library.link/vocab/subjectName
  • triangular cases
  • allocation of profits
  • tax treaty
  • capital gains tax
Label
A critical evaluation of the New Zealand and Australian governments' solution to triangular taxation relief : Part two
Instantiates
Publication
Label
A critical evaluation of the New Zealand and Australian governments' solution to triangular taxation relief : Part two
Publication

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