House of Representatives

Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Bill 2013

Explanatory Memorandum

(Circulated by the authority of the Deputy Prime Minister and Treasurer, the Hon Wayne Swan MP)

References in this part of the Explanatory Memorandum are to the provisions of Part IVA as they applied prior to the amendments made by Schedule 1 of this Bill.

A tax benefit from eliminating a liability to withholding tax is also provided for by section 177CA in the current law.

DSG Retail Ltd; Mastercare Coverplan Service Agreements Ltd; Mastercare Service and Distribution Ltd [2009] UKFTT 31 (TC)