How does Covid change ‘corporate residency’, ‘source’ and ‘permanent establishment’ in the world of international taxation?

Tax Month - September 2021

The traditional ‘gateways’ to taxation, around the world, have been ‘residence’, ‘source’, and ‘permanent establishments’. These have been under pressure, for some time now, as technology makes all these more ambiguous. Covid-19 has recently exacerbated this, in some dramatic ways. Lockdowns, closed borders, people trapped in the country they were in, people retreating home, people…

GST – WYPF v CofT – ACT developer could not deduct $77m of ‘Building Works’ under the margin scheme’ but did get a refund for a margin overstated by $29m of ‘Preparatory Works’

Tax Month - August 2021

On 25 August 2021, the AAT decided a GST case: WYPF v CofT, in which it held that an ACT developer, of new residential premises, could not reduce the ‘margin’, on which GST is payable, under Div 75 of the GST Act, by $77m cost of its ‘Building Works’. The ATO accepted that both the…

‘Childminding’ for Victorian Covid ‘Authorised Workers’ – 4th change in restrictions in 12 days – ok if child enrolled in primary school

Tax Month - August 2021

In Victoria, we’re no longer alone in being pretty Covid weary, but spare a thought for our Authorised Workers, who’ve just had the 4th change, in 12 days, in restrictions affecting whether they can get childminding. The latest change relaxes restrictions, so childminding is now available, but only if the child is enrolled in primary…