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Alternative Market Briefing

PwC Australia writes on the new investment manager regime for AIMA Journal

Friday, June 21, 2013

Beverly Chandler, Opalesque London: Writing in the AIMA Journal, PwC Australia’s tax team of Ken Woo, Tax Partner, Grahame Roach, Tax Director, and Darren Mack, Tax Director, PwC Australia discussed Australia’s new investment manager regime.

The team writes: "Australia is in the process of finalising its own investment manager regime (IMR) with the aim to reduce tax uncertainty, and disincentives for certain widely held funds seeking to invest in Australia and use Australian intermediaries. Foreign funds that are unable to rely on a tax treaty with Australia have been potentially exposed to Australian tax on gains on Australian investments, and on foreign investments where the use of an Australian intermediary gave rise to a permanent establishment."

Australia’s IMR has been introduced in three parts through a series of announcements, consultations, draft legislation and enacted law. The PwC team explains that the final tranche (or Element 3) of the IMR was released as an exposure draft legislation on 4 April 2013.

"Broadly, these new rules will operate retrospectively from the 2012 income year. The legislation provides an exemption from Australian income tax available for certain widely held foreign funds on portfolio (and in certain cases some non-portfolio) investments, and limits the exemption to......................

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