Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.
I have written before about how corporate tax principles are very relevant to the taxation of individuals. This is true also of the disguised investment management fee (DIMF)rules where transfer pricing forms the basis of taxation for internationally mobile investment managers receiving investment management fees.
This article also considers some of the complexities arising as a result of entity classification in investment management structures and how this affects the enjoyment conditions under which an individual is deemed to receive fees of another person.
Sums arising to third parties: exclusions
Where the enjoyment conditions of ITA 2007 s 809EZDB are satisfied an individual can be treated as receiving investment management fees which are in fact received by another person.
The enjoyment...
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Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.
I have written before about how corporate tax principles are very relevant to the taxation of individuals. This is true also of the disguised investment management fee (DIMF)rules where transfer pricing forms the basis of taxation for internationally mobile investment managers receiving investment management fees.
This article also considers some of the complexities arising as a result of entity classification in investment management structures and how this affects the enjoyment conditions under which an individual is deemed to receive fees of another person.
Sums arising to third parties: exclusions
Where the enjoyment conditions of ITA 2007 s 809EZDB are satisfied an individual can be treated as receiving investment management fees which are in fact received by another person.
The enjoyment...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
