Do you know a non-resident will generally be able to avail themselves of a capital gains tax exemption to the extent that it disposes of a non-portfolio interest in a company provided that company is not land rich?
From an exit tax perspective, it is preferred to run the Australian operations through a subsidiary as opposed to a branch. Of course, there are many commercial variations to this long term objective that balance the risk and cost issues in the short term yet, if managed, can still achieve the preferred exit tax preference.
For more information, contact Matt Zhou on 02 9957 4033
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