ey-global-tax-policy-outlook-for-2015

Australia
• Thin capitalization
• Thin-capitalization rules are tightening, including a reduced
main safe harbor to broadly a 1.5:1 ratio of debt to assets
(60% debt) from 1 July 2014.
• The Board of Taxation is currently reviewing the thin
capitalization arm’s-length debt test. The report is expected
to be provided to the Assistant Treasurer by the end of 2014.
• Transfer pricing changes
Higher burden in 2015
• Administrative guidance in relation to Australia’s transfer
pricing and reconstruction provisions (enacted in 2013) is
•
Higher burden in 2015
• Legislation currently before Parliament to:
•
of A$20 billion or more
•
of the proposed reduction in the CIT rate
•
amortization
Higher burden in 2015
•
after 1 July 2014 is intended to encourage investment in
minerals exploration” in Australia.
•
A$100 million over three years (A$25 million in 2015–16).
• Changes to tax enforcement approach
Higher burden in 2015
•
Jordan is continuing to reinvent its approach, including
the client experience for “willing participants,” seeking
effectiveness.
• Commissioner Jordan is leading initiatives around
multilateral joint audits of global corporates (through the
• Top marginal personal income tax (PIT) Rate
Higher burden in 2015
• The Medicare levy rate increased from 1.5% to 2% of
taxable income starting with the 2014-15 income year.
The Temporary Budget Repair levy of 2% is effective from
1 July 2014 until 30 June 2017, so the top marginal rate
• PIT base
38 | The outlook for global tax policy in 2014