Board of Taxation
August 2011
© Commonwealth of Australia 2011
ISBN 978-0-642-74771-6
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Source: Board of Taxation, Design of an Investment Manager Regime as it relates to foreign managed funds: A report to the Assistant Treasurer (September 2011).
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- Executive summary
- Chapter 1: Introduction
- Chapter 2: Design principles of an IMR for foreign managed funds
- Chapter 3: Appropriateness of an exemption style IMR
- Chapter 4: Definition of foreign managed funds
- Chapter 5: Types of exempt investment income
- Chapter 6: Protecting the Australian tax base
- Chapter 7: Taxation of Australian based intermediaries
- Appendix A: List of Board's recommendations
- Appendix B: Overview of other jurisdictions
- Appendix C: List of information exchange countries
Foreword
The Board of Taxation is pleased to submit this report to the Assistant Treasurer following its review of the design of an Investment Manager Regime as it relates to foreign managed funds. This report forms part of the Board’s review of tax arrangements applying to Collective Investment Vehicles which is due for reporting to the Government by 31 December 2011.
The Board has made a number of recommendations that seek to remove tax impediments to international investment into Australia by foreign managed funds and impediments to the use of Australian intermediaries by these funds.
The Board established a Working Group, chaired by John Emerson AM, to conduct the review. The Board held discussions with a range of stakeholders, issued a discussion paper, and received 35 submissions, 16 of which provide input in relation to the Investment Manager Regime. The Board would like to thank all of those who so readily contributed information and time to assist in conducting the review.
The Board would also like to express its appreciation for the assistance provided to the Working Group by Michael Brown, Alexis Kokkinos, Andrew Mills, Karen Payne and Ken Woo as members of the Expert Panel, by Richard Vann as a consultant engaged by the Working Group, and by officials from the Treasury and the Australian Taxation Office.
The ex officio members of the Board — the Secretary to the Treasury, Dr Martin Parkinson PSM, the Commissioner of Taxation, Michael D’Ascenzo AO, and the First Parliamentary Counsel, Peter Quiggin PSM — have reserved their final views on the recommendations in this report for advice to Government.
| Chris Jordan AO Chairman, Board of Taxation |
John Emerson AM Chairman of the Board’s Working Group Member, Board of Taxation |