We advise on double tax agreement (tax treaty) issues and withholding tax obligations on cross-border payments. This includes reviewing agreements, payment characterisation and practical compliance obligations where amounts are paid offshore (for example, interest, royalties or other payments that may attract withholding tax). We also assist with treaty-based positions, including reduced rates and documentation support.

We help private groups with inbound and outbound structuring, including market entry planning and cross-border ownership arrangements. This includes high-level advice on branch vs subsidiary considerations, funding pathways, and structuring options that align tax, commercial and asset protection objectives.

A change in residency can affect what is taxed in Australia, how entities are treated, and how future transactions are managed. We advise on changing tax residency, both inbound and outbound, including pre-move planning, post-move implementation, capital gains tax cost base setting, and the impact on trusts, SMSFs, companies, partnerships, control and distributions.

A business can create a taxable presence in another country — or in Australia — without incorporating there. We assist with assessing whether activities may create a permanent establishment (PE) and provide guidance on PE profit attribution where a taxable presence exists. This includes reviewing where services are performed, who has authority to contract, and the practical operating footprint of the business.

For private groups with international related-party transactions, we provide high-level transfer pricing support, including:

• simplified transfer pricing record keeping protocols
• transfer pricing documentation and policy support
• related-party loan pricing reviews
• intercompany agreement alignment (tax, legal and accounting)
• review readiness for ATO scrutiny of international related-party dealings

Our aim is to keep transfer pricing support proportionate while maintaining a defensible position.

Cross-border financing is a major risk area for private business. We provide advice on thin capitalisation, related-party loan structures and broader international financing integrity issues, including debt deduction creation rules (DDCR) and hybrid mismatch rules (where relevant). We also review funding structures for acquisitions, expansions and restructures to identify interest deductibility and documentation risks early.

We assist with international tax compliance and disclosures, including the International Dealings Schedule (IDS). This includes assessing whether an IDS is required, identifying relevant transactions, reconciling disclosures to financial records, and improving annual reporting consistency across entities. We also help clients build better cross-border tax governance as their international dealings grow.

Where Australian residents have interests in foreign companies (including inherited assets), we advise on controlled foreign company attribution and related cross-border structuring issues. We also provide repatriation planning support — helping private groups and the owners of those private businesses, think through how profits are brought back to Australia (or distributed through a group) in a tax-aware, fact based and compliant way.

This may include high-level guidance on:

• foreign income tax offsets (FITO) / double tax relief
• interaction with withholding tax and foreign tax paid
• distribution timing and structure
• franking credit streaming rules and related integrity considerations

Many international tax issues for private businesses start with indirect tax rather than income tax. We advise on high-level GST/VAT on cross-border supplies, including supply characterisation, invoicing issues and practical compliance pathways. Where relevant, we also coordinate with specialists on customs duty, import GST and tariff matters.