The MAAL and the proposed Diverted Profits Tax - a comparative

The MAAL and the diverted profits tax - a comparative by Joanne Dunne, CTA, Partner, MinterEllison, Melbourne

COVER

A diverted profits tax was proposed by the federal government in the 2016-17 Budget. A multinational anti-avoidance law (MAAL) was enacted in late 2015. Both the MAAL and the diverted profits tax focus on multinationals that derive $1b or more in group income. The diverted profits tax is proposed to be applicable for income years following 1 July 2017, but to arrangements whenever they were entered into. This means that the development of the diverted profits tax should be closely monitored and risk mitigation should be considered. This article compares the MAAL and the diverted profits tax to demonstrate where they intersect and the differences between them, and to highlight how these regimes provide a new framework for multinational taxation in Australia. The article also considers example structures to demonstrate where the MAAL and proposed diverted profits tax provide the ATO with two additional avenues to attack structures which concern it.

Comparison between the MAAL and the diverted profits tax

Issue

Who it applies to

MAAL

Sianificant global entities, re entities with annual global income or consolidated oroup inCome of ,S1b or more.

Proposed diverted profits tax

The consultation paper' issued by Treasury on 3 May 2016 states that the purpose of the diverted profits tax is:

• to provide the ATO with greater powers to deal with taxpayers who transfer profits, assets or risks to offshore related parties using artificial or contrived arrangements to avoid Australian tax and who do not cooperate with the ATO; and

• to ensure that entities operating in Australia cannot avoid Australian taxation by transferring profits, assets or risks offshore through related party transactions that lack economic substance, and to discourage multinationals from delaying the resolution of transfer pricing disputes.

The consultation paper suggests that integrity measures such as the MAAL were difficult to enforce where a taxpayer was not cooperative; hence the need for a diverted profits tax.

Significant global entities, ie entities '.5th global income or consolidated group income of Sib or more .andi

Comrnent

The consultation paper on the diverted profits tax suggests that there is intentional intersection with the MAAL to some degree. However, the diverted profits tax seems to be a proposal designed to incentivise multinationals to agree to adjustments under other provisions, such as the MAAL or transfer pricing provisions.

both regimes are intended to apply only to significant global entities,

some differences arise.

Purpose The explanatory memorandum to the Tax Laws Amendment (Combating Multinational Avoidance) Bill 2015 (0th) states that the purpose of the multinational anti-avoidance law (MAAL) is to counter the erosion of the Australian tax base by multinational entities using artificial or contrived arrangements to avoid the attribution of business profits to Australia through a taxable presence in Australia.

• that are Australian tax residents or have an Australian permanent establishment: and

• that have Australian turnover of S25m or more — unless the Australian turnover is less than $ because income is ar tifici:* hooked

offshore rather than in Australia.

The, diverted protits tax only applies vvnere there are Australian operations which have a S25m or greater Australian

tumoi,,,er, and the consultation paper states that this threshold is intended to identify taxpayers of lower risk, and to align i,vith other thresholds. such as the S2f5m threshold applying to provide for simplified transfer pricing

TAXATION IN AUSTRALIA I VOL 51(1) 21

COVER

Comment

record-keeping requirernents.2 It is also notable that there is intended to be an "artificiality" test to be applied by the ATO when determining whether that Australian turnover level is breached. No further detail is provided.


Date in effect ' 1 January 2016

0When it can The MAAL can apply where: eapply is there is a scheme under which a

• the foreign entity obtains ordinary -income or statutory income from the supply;

is some or all of that income is not attributable to an Australian permanent establishment of the foreign entity; and

• it can be concluded that the scheme was entered into for the principal purpose or a principal purpose of enabling a taxpayer to reduce Australian taxes or reduce Australian and foreign taxes (with a deferral of foreign tax being relevant unless there are reasonable commercial grounds for the deferral). The specified factors taken into account include the extent of activities performed in Australia and outside of Australia relating to the supply.

foreign entity in the group supplies goods and/or services (other than equity interests, debt interests or options over equity or debt interests) to unrelated Australian customers;

la activities are undertaken in Australia directly in connection with the supply;

the Australian activities are undertaken in whole or in part by an associated Australian entity or an Australian permanent establishment of the foreign entity, or by an unassociated Australian entity that is commercially dependent on the foreign entity;

Proposed to be effective for income years on or after 1 July 2017 but can apply to arrangements whenever they were entered into. There is no legislation as yet.

The diverted profits tax can apply Some differences arise.

The MAAL is focused on multinational • there is an effective tax mismatch, ie: groups which may or may not have

• there is a transaction between the associated Australian operations. The Australian taxpayer and a related MAAL focuses on transactions with

unrelated Australian customers and considers what part an associated Australian operation or unassociated Australian operation (where there is commercial dependence) plays in the transactions with those customers. The MAAL does not have a de minim's Australian turnover threshold before ..

applicable. The taxpayer's Australian tax liability, a principal purpose test which is a For example, if there is a $100 different test to the remainder of Pt IVA reduction in the Australian of the Income Tax Assessment Act 1936 taxpayer's Australian tax liability (Cth) (ITAA36). as a result of a deductible fee, but the related party only pays The diverted profits tax focuses on

$60 of tax on the fee income multinational groups which definitely

in its jurisdiction, there is an have Australian operations, where those operations derive Australian turnover above a $25m de minim's level. It is focused on transactions between the Australian taxpayer and a related party in the multinational group. The diverted profits tax does not include a purpose test, rather it applies a "design" test.

there is insufficient economic As is demonstrated by the structure

substance, le it can be reasonably examples below, there are situations concluded based on the information where the MAAL and diverted profits

available to the ATO that the tax can both be applicable, but the

transaction at issue or structure at diverted profits tax is of potentially wider

issue was designed to secure a tax application •

reduction.

When considering the insufficient economic substance test, if it can be shown that the non-tax ficancial benefits exceed the financial benefit of the tax reduction, then there may be economic substance, and the diverted profits tax may not be applicable.

where:

party cross-border;

the transaction reduces the Australian taxpayer's Australian tax; and -

the transaction increases the related party's tax, but by less than 80% of the corresponding reduction in the Australian

effective tax mismatch. Note: factors which might cause that tax mismatch to arise, such as the application of tax relief in a foreign jurisdiction, are not taken into account when considering if a mismatch arises; and

22 TAXATION IN AUSTRALIA I JULY 2016

COVER

MAAL

The MAAL applies at the corporate tax rate (30%)* on Australian income that ought to have been returned in Australia (the Commissioner will determine the arm's length profits attributable to Australia) plus an additional potential penalty of 100% of unpaid taxes,— and interest.

It is possible for the MAAL to apply to a small Australian business that is part of a multinational group — potentially at the small business tax rate of 28.5% (or 27.5% if the 2016-17 Budget measures are passed).

** Penalties can be up to 120% if aggravating factors arise, such as obstructing an ATO officer. The 100% penalty can be reduced if it can be shown that the taxpayer's position was reasonably arguable.

Proposed diverted profits tax _ _ The diverted profits tax applies at 40%.

Interest will also be imposed from the date any amount would have been subject to income tax to the date of the provisional diverted profits tax assessment. While it is not mentioned directly in the consultation paper, depending on taxpayer behaviour, penalties may be applicable as well.

The diverted profits tax can apply in situations where income arising between offshore entities is attributed to Australia. The consultation paper suggests that in that scenario, when determining the diverted profits amount on which the diverted profits tax will . apply, the ATO may take into account Australian tax regimes that would have applied had the profits at issue been brought to tax in Australia.

For instance, to use a simple example referred to in the consultation paper:

• Foreign Co is equity funded by Foreign Parent Co and uses the funding ($300m) to acquire an asset;

• a related Australia Co leases the asset from Foreign Co, and claims a deduction in Australia for the lease costs of $30m; and

• assume that the ATO takes the view that the diverted profits tax tests (effective tax mismatch and insufficient economic substance) are satisfied.

The diverted profits tax operates in this example if the ATO concluded that absent the above structure, Foreign Parent Co would have equity funded Australia Co and Australia Co would have held the asset. The diverted profits amount would be calculated as $30m (being the lease payment made, which

Comment

, The diverted profits tax rate is : deliberately penal in nature.

The consultation paper states that the rate has been set "to encourage

• taxpayers to pay the lower corporate tax rate through complying with Australia's tax rules".

• It is also notable that the diverted profits tax sets out an expanded seven-year statutory time bar (like the transfer pricing time bar period), strict timeframes for response by taxpayers

• to a provisional diverted profits tax . assessment, and then cut-down

timeframes for the ATO to conclude its diverted profits tax assessment. This assessment process is further explained in detail in the consultation paper.

The MAAL assessment process is consistent with Pt IVA assessment

• processes, and the MAAL does not have any specifically designed assessment process. The MAAL gives the ATO the option of either attributing income to an Australian related subsidiary, or deeming a permanent establishment of the offshore entity to

• arise, and attributing income to that deemed permanent establishment.

There is some degree of similarity between the regimes in relation to the calculation of income — particularly in focusing on what would have been the , position had the scheme or transaction at issue not occurred.

Issue

The rate of tax

How the As the MAAL is an anti-avoidance fr,income that . measure, the ATO has powers under P.

subject Pt IVA to reconstruct the scheme to to the tax is counter the tax benefit obtained. t calculated The ATO will assume that the foreign

entity had a permanent establishment in Australia and that some or all of the activities of the foreign entity were undertaken by and attributable to that deemed permanent establishment, and apply tax to that attributed amount.

In its MAAL client experience roadrnap3 and in LOG 2015/2,4 the ATO suggests that when determining the income to which the MAAL could apply, it is for the taxpayer to prepare a functional analysis and profit attribution as it would under the transfer pricing regime. This may of course allocate deductible expenses that would have been applicable to any such deemed permanent establishment. LCG 2015/2 also states that compensating adjustments can be requested by a taxpayer and determined by the Commissioner under s 177F(1) ITAA36 to take into account tax deductions or benefits that would have been available had the scheme not been entered into.


Where the regime sits in the income tax legislation

In Pt IVA.

COVER

Issue MAAL Proposed diverted profits tax

represents diverted profits) less an amount representing the depreciation that Australia Co would have claimed. 40% tax would be calculated by the ATO on that net amount.

It should be noted that the diverted profits tax can apply widely, including as-an adjunct to the transfer pricing rules to attack excessive expenses paid to related parties. In this event, the diverted profits amount on which the tax is applied would be the tax benefit from the excessive expense (le (generally) 30% of the excessive expense).

The diverted profits tax will not provide a credit for any foreign tax paid, but a credit may be available for Australian tax paid on any diverted profits amount brought to Australian tax (eg under the controlled foreign company rules).

Not clear yet.

Comment

This is an important issue when considering Australia's double tax treaty obligations. While the MAAL is not an issue in this respect as it sits in Pt IVA and s 4(2) of the International Tax Agreements Act 1953 (Cth) gives primacy to Pt IVA, it is not clear where the diverted profits tax will sit in the income tax legislation. Given the manner in which it is described in the consultation paper, it does not seem the diverted profits tax will be part of Pt IVA although, in the absence of actual

• legislation, that is uncertain at this stage.

, The diverted profits tax can seek to , impose tax in relation to business profits

derived by an entity resident in another contracting state. This is in the scenario where profits are derived between two

• foreign entities in a multinational group, and the ATO seeks to use the diverted profits tax to reconstruct the transaction and attribute some of that income to Australia. The business profits article

' in an applicable double tax treaty . may be applicable to provide relief

from the diverted profits tax in those circumstances. The issue is whether the

. diverted profits tax is a tax that could be covered by a double tax treaty.

In a number of Australia's double tax treaties (eg NZ-Australia Treaty, US-Australia Treaty), "tax" is defined in art 3 as excluding "any penalty or interest imposed under the law of either contracting state relating to its tax". It may be that Australia seeks to maintain that despite its title as a "tax", the diverted profits tax is a "penalty". This would mean that those double tax treaties would not affect Australia's right to impose the diverted profits tax.


Issue MAAL

Where the regime sits in the income tax legislation

In Pt IVA.

COVER


represents diverted profits) less an amount representing the depreciation that Australia Co would have claimed. 40% tax would be calculated by the ATO on that net amount.

It should be noted that the diverted profits tax can apply widely, including as an adjunct to the transfer pricing rules to attack excessive expenses paid to related parties. In this event, the diverted profits amount on which the tax is applied would be the tax benefit from the excessive expense fie (generally) 30% of the excessive expense).

The diverted profits tax will not provide a credit for any foreign tax paid, but a credit may be available for Australian

r tax paid on any diverted profits amount brought to Australian tax (eg under the controlled foreign company rules). , _ Not clear yet.

Comment

This is an important issue when considering Australia's double tax treaty obligations. While the MAAL is not an issue in this respect as it sits in Pt IVA and s 4(2) of the International Tax Agreements Act 1953 (Cth) gives primacy to Pt IVA, it is not clear where the diverted profits tax will sit in the income tax legislation. Given the manner in which it is described in the consultation paper, it does not seem

, the diverted profits tax will be part of Pt IVA although, in the absence of actual legislation, that is uncertain at this stage.

The diverted profits tax can seek to impose tax in relation to business profits derived by an entity resident in another contracting state. This is in the scenario

. where profits are derived between two foreign entities in a multinational group, and the ATO seeks to use the diverted profits tax to reconstruct the transaction and attribute some of that income to Australia. The business profits article in an applicable double tax treaty may be applicable to provide relief from the diverted profits tax in those circumstances. The issue is whether the diverted profits tax is a tax that could be covered by a double tax treaty.

In a number of Australia's double tax treaties (eg NZ-Australia Treaty, US-Australia Treaty), "tax" is defined in art 3 as excluding "any penalty or interest imposed under the law of either contracting state relating to its tax". It may be that Australia seeks to maintain that despite its title as a "tax", the diverted profits tax is a "penalty". This would mean that those double tax treaties would not affect Australia's right to impose the diverted profits tax.

24 TAXATION IN AUSTRALIA JULY 2016

Unrelated Australian customers

Cloud Computing Sub Australia

(5) Sales revenue

Singapore Cloud Computing Co

(3) Marketing and negotiating bespoke contracts including price with customers

(2) Fee

(1) Marketing services

COVER

Issue MAAL Proposed diverted profits tax Comment

In Australia's older treaties (eg Singapore—Australia Treaty), that penalty exclusion is not explicit, and instead the treaty provides that it applies to Australia's income tax or "any identical or substantially similar taxes". In relation to those treaties, it may be that Australia seeks to maintain that the diverted profits tax is not an "income tax" and is also not substantially similar to an income tax, but is a new tax or a penalty that is not an "income tax". That was the position taken by HM Revenue & Customs in the United Kingdom when it enacted its own diverted profits tax (to some criticism). This argument could support the view that those older double tax treaties would not affect Australia's right to impose the diverted profits tax.

This issue will need to be clarified prior to the enactment of the proposed diverted profits tax.

Example structures

1. Sales revenue booked offshore: MAAL and diverted profits tax intersect, both potentially applicable

(4) Finalise sale, sign contract

MAAL The MAAL could apply in this circumstance. This is because Cloud Computing Sub Australia carries out most of the functions to secure the contracts with the unrelated Australian customer, including contract negotiation, pricing and bespoke terms. Little real activity could be perceived to occur in Singapore where the contracts are concluded. It could be concluded that the principal purpose of the arrangement is to ensure that Australian tax is not paid on the profits from Australian sales. The multinational is at risk of the MAAL applying. If the MAAL applied, profits from Australian sales could be attributed to Cloud Computing Sub Australia or to a deemed permanent establishment of Singapore Cloud Computing Co, with that attributed income subject to Australian tax at 30%.

Diverted profits tax

Assuming that the tax rate applicable in Singapore is less than 80% of Australia's rate, the issue will be whether the arrangement with Singapore Cloud Computing Co has insufficient economic substance. The issue will be whether the information available to the ATO might lead it to conclude that the structure was designed to secure a tax reduction in Australia. It will also be critical to consider the non-tax financial benefits of the structure and compare those to the value of the tax reduction. The diverted profits tax could subject Australian sales income to tax at 40%.


(3) Loan from Parent (1) Administrative

services

(2) Fee


(4) Interest payment

COVER

2. Sales revenue booked offshore: MAAL may not be applicable, diverted profits tax may still apply


(1) Marketing/customer solicitation service

(4) Negotiate and conclude contracts, including price

(6) Sales revenue

AND (2) Fee

(5) Finalise Unrelated Australian customers


(3) Marketing — providing introduction to Singapore Cloud Computing Co — no involvement in contract provision, finalisation or negotiation

MAAL Example 3.6 and example 3.8 in the

explanatory memorandum to the Tax Laws (Combating Multinational Avoidance) Bill

2015 (Cth) suggest that the MAAL should

not be applicable in this situation as it

cannot be concluded that the scheme was

entered into for the or a principal purpose

of enabling a taxpayer to reduce Australian

taxes. This is because of the lack of any

involvement by Cloud Computing Sub

Australia in concluding sales contracts with

Australian customers.

Diverted profits tax It seems possible for the diverted profits

tax to nonetheless be applicable — even

where the MAAL does not apply. Assuming that tax rate applicable in Singapore is less

than 80% of Australia's rate, the issue will

be whether Singapore Cloud Computing

Co has insufficient economic substance.

The issue will be whether the information

available to the ATO might lead it to

conclude that the structure was designed

to secure a tax reduction in Australia, and

whether any non-tax financial benefits can

be shown to exceed the tax benefits from

the structure. It will be important to ensure

that the ATO has sufficient information so

that it does not reach that conclusion. It

seems most likely that where the MAAL

does not apply the diverted profits tax

ought not apply either. The point to note

is that the diverted profits tax imposes a

lower standard, there is no purpose test,

and the ATO may be able to use the tax in

circumstances where Pt IVA requirements

may be more onerous.

3. Deductible payment between related parties: MAAL is not applicable, diverted profits tax could apply


Hong Kong Parent Cloud Computing Co

MAAL The MAAL is not relevant to this example.

There is no supply of goods and services

to unrelated Australian customers.

Diverted profits tax The diverted profits tax can apply.

The fee paid for administrative services could be deductible to Cloud Computing

Sub Australia and, assuming Singapore's

applicable tax rate is less than 80% of

Australia's rate, there is an effective tax mismatch. In terms of whether there is

insufficient economic substance, the value

of the services to Cloud Computing Sub

Australia commercially will need to exceed

the financial benefit of the tax reduction.

This may be difficult to establish. The

consultation paper states that the diverted

profits amount will be 30% of the fee

(being the tax benefit obtained from the

deductible fee), and the 40% tax will be

imposed on that amount.

The administrative fee example

demonstrates clear intention to use the

diverted profits tax as a mechanism to

enforce the transfer pricing rules. The ATO

will be able to strategically impose the

diverted profits tax where it is not satisfied

as to compliance with transfer pricing

documentation requirements and with the

amount of a fee. Agreeing to a transfer

pricing adjustment instead leads to a lower

rate of tax (30%) being applied than the

40% diverted profits tax.

The diverted profits tax could also apply

to the loan. Again, this assumes an

interest deduction for Cloud Computing

Sub Australia, and the applicable tax rate

in Hong Kong being less than 80% of

Australia's rate. It also assumes that the

ATO can conclude that there is insufficient economic substance to the structure —

particularly that the commercial benefits

do not outweigh the benefit of the tax


COVER

2. Sales revenue booked offshore: MAAL may not be applicable, diverted profits tax may still apply


(1) Marketing/customer solicitation service

(4) Negotiate and conclude contracts, including price

(6) Sales revenue

AND (2) Fee

(5) Finalise Unrelated Australian Cloud Computing customers Sub Australia

(3) Marketing - providing introduction to Singapore Cloud Computing Co - no involvement in contract provision, finalisation or negotiation

MAAL Example 3.6 and example 3.8 in the

explanatory memorandum to the Tax Laws (Combating Multinational Avoidance) Bill

2015 (Cth) suggest that the MAAL should

not be applicable in this situation as it

cannot be concluded that the scheme was

entered into for the or a principal purpose

of enabling a taxpayer to reduce Australian

taxes. This is because of the lack of any

involvement by Cloud Computing Sub

Australia in concluding sales contracts with

Australian customers.

Diverted profits tax It seems possible for the diverted profits

tax to nonetheless be applicable — even

where the MAAL does not apply. Assuming

that tax rate applicable in Singapore is less

than 80% of Australia's rate, the issue will

be whether Singapore Cloud Computing

Co has insufficient economic substance.

The issue will be whether the information available to the ATO might lead it to

conclude that the structure was designed

to secure a tax reduction in Australia, and whether any non-tax financial benefits can

be shown to exceed the tax benefits from

the structure. It will be important to ensure

that the ATO has sufficient information so

that it does not reach that conclusion. It

seems most likely that where the MAAL

does not apply the diverted profits tax

ought not apply either. The point to note

is that the diverted profits tax imposes a

lower standard, there is no purpose test,

and the ATO may be able to use the tax in

circumstances where Pt IVA requirements may be more onerous.

3. Deductible payment between related parties: MAAL is not applicable, diverted profits tax could apply


Hong Kong Parent Cloud Computing Co

1

(2) Fee

(1) Administrative services

(3) Loan from Parent

(4) Interest payment


MAAL The MAAL is not relevant to this example.

There is no supply of goods and services

to unrelated Australian customers.

Diverted profits tax The diverted profits tax can apply.

The fee paid for administrative services

could be deductible to Cloud Computing Sub Australia and, assuming Singapore's

applicable tax rate is less than 80% of

Australia's rate, there is an effective tax

mismatch. In terms of whether there is

insufficient economic substance, the value of the services to Cloud Computing Sub

Australia commercially will need to exceed

the financial benefit of the tax reduction.

This may be difficult to establish. The

consultation paper states that the diverted

profits amount will be 30% of the fee

(being the tax benefit obtained from the

deductible fee), and the 40% tax will be

imposed on that amount.

The administrative fee example

demonstrates clear intention to use the

diverted profits tax as a mechanism to

enforce the transfer pricing rules. The ATO

will be able to strategically impose the

diverted profits tax where it is not satisfied

as to compliance with transfer pricing

documentation requirements and with the amount of a fee. Agreeing to a transfer

pricing adjustment instead leads to a lower

rate of tax (30%) being applied than the 40% diverted profits tax.

The diverted profits tax could also apply

to the loan. Again, this assumes an

interest deduction for Cloud Computing

Sub Australia, and the applicable tax rate

in Hong Kong being less than 80% of

Australia's rate. It also assumes that the

ATO can conclude that there is insufficient economic substance to the structure —

particularly that the commercial benefits

do not outweigh the benefit of the tax


24TH NO.OSA. . TAX INTENSIVE The SME Operating Theatre — Is a Check-up Sufficient or Do You Need Radical Surgery? Those in the profession of giving tax advice to SME clients urgently need to mark the 10th and llth of November in your diaries to attend the 24th Noosa Tax Intensive. You won't want to miss the compelling line-up of speakers and valuable networking opportunities, all presented to you in the incomparable surrounds of Noosa.

10-11 November 2016 Sofitel Noosa Pacific Resort

THE TAX INSTITUTE

PROGRAM To register your interest contact AVAILABLE Carlie Lemon on 07 3225 5200 or SOON [email protected]

COVER

reduction in Australia. The consultation

paper states that the loan falls within thin capitalisation safe harbours that protects

the amount of debt, but the diverted

profits tax could still apply to the "pricing of the debt" — presumably the interest

rate. Again, it seems that the diverted

profits tax is a back up to transfer pricing

provisions in this regard. The consultation

paper suggests that the actual amount of debt could also be challenged assuming

thin capitalisation safe harbours are not

met; again, a back up to transfer pricing

adjustment provisions as well as to the

thin capitalisation regime. However, if thin

capitalisation safe harbours are not met, there may be no interest deduction and

it is hard to see what the tax reduction is

in Australia giving rise to an effective tax

mismatch. The point to note is that diverted

profits tax potentially has a wide reach,

particularly given the UK's diverted profits

tax carves out most loans, in main part on

the basis that its thin capitalisation and

transfer pricing rules effectively manage the issue.

Joanne Dunne, CTA Partner MinterEllison, Melbourne

References

1 Treasury, Implementing a diverted profits tax, consultation paper, 3 May 2016.

2 ATO, "Simplifying transfer pricing record keeping", ATO guide, January 2016. Available at www.ato.gov. au/business/international-tax-for-busIness/in-detail/ transfer-pricing/simplifying-transfer-pricing-record-keeping/.

3 ATO, MAAL client experience roadmap, a guide to assist taxpayers transition to compliance with the new MAAL provisions, 12 January 2016. Available at www.ato.gov.au/law/view/pdf/cgl/maal_client_ experience_roadmap.pdf.

4 LCG 2015/2. Available at www.ato.gov.au/law/view/ yiew.htm?srcehs&pit=99991231235958&aro=false&s tart.18.pageSize=108,total=1&num=0&docid-COG% 2FLCG20152%2FNAT%2FATO%2F00001&dc=false&t m=and-basic-Icg 2015%2F2#P29.

TAXATION IN AUSTRALIA VOL 51(1) 27

The MAAL and the proposed Diverted Profits Tax - a comparative

Law

Transcript of The MAAL and the proposed Diverted Profits Tax - a comparative