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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