*Restriction on immediate deduction for mining rights and information [8]

Expenditure on mining rights and information will no longer qualify for an immediate deduction. According to the Government, this change will address situations where an immediate deduction is being claimed for the costs of acquiring an interest in natural resources that have effectively already been discovered. Mining rights and information first used for exploration will…

*Package of measures targets multinational profit shifting structures: thin cap ratios reduced; CFCs; foreign exempt income; non-portfolio dividends; etc [3]

The Government announced that it would address profit shifting by multinationals through the disproportionate allocation of debt to Australia by tightening and improving the integrity of several aspects of Australia’s international tax arrangements, with effect for income years commencing on or after 1 July 2014. The Government expects this to have an estimated gain to revenue of…

*Preventing “dividend washing” and doubling up of franking credits [6]

In the Budget, the Government announced it would close a loophole that enables sophisticated investors to engage in “dividend washing” (although known as dividend double-dipping). Currently, sophisticated investors can engage in “dividend washing” to, in effect, trade franking credits. This can result in some shareholders receiving two sets of franking credits for the same parcel…

*Changes to Australia’s foreign resident CGT regime – the ‘principal asset’ test in the ‘Taxable Australian Real Property’ or TARP Test [4]

This involves changes to the ”principal asset” test in Subdiv 855-A of the ITAA 1997 to ensure that indirect Australian real property interests are taxable if disposed of by a foreign resident. This change consists of 2 components. First, intercompany dealings between entities in the same tax consolidated group will not form part of the…

*Confirmation that self-education expenses to be capped at $2,000 pa [9]

The Budget Papers confirmed the Treasurer’s 13 April 2013 announcement (see April 2013 Developments) that the Government would introduce a $2,000 cap on tax deduction claims for work-related self-education expenses per person from 1 July 2014. The announcement was made “as part of a package of reforms to make a down-payment on the National Plan for School Improvement”. Taxpayers…

*Further extension of monthly PAYG instalments to big non-corporate entities [10]

The Government will extend the requirement to make monthly PAYG income tax instalments to include all large entities in the PAYG instalment system, including trusts, superannuation funds, sole traders and large investors. The Government has already announced that corporate tax entities with turnover of more than id=”mce_marker”bn will move to monthly PAYG instalments from 1 January 2014;…