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Foreign resident vessels and cross border vessel leasing in Australia

Foreign resident vessels and cross border leasing

In 2016, the Australian Taxation Office (ATO) released a Taxpayer Alert raising significant concerns around the operation of leasing structures in Australia.


Director, Transfer Pricing

KPMG Australia


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Cross border leasing is now a significant focus area for the ATO – audit activity is being undertaken in relation to leasing structures and additional ATO guidance is being drafted.

As part of the ATO policy for development and consultation, KPMG has been participating in the consultation process. KPMG hosted a webinar on 6 April 2017, exploring interactions with the ATO, including:

  • common leasing structures
  • withholding tax issues relating to different structures
  • anti-avoidance reconstruction issues
  • new transfer pricing rules and bareboat charter payments
  • the US perspective on leasing arrangements
  • the UK perspective on leasing arrangements.

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