Public Consultation on the Multinational Anti‑avoidance Law

By Robert Robillard - 13 May 2015

This blogpost originally appeared on

The Australian government also announced a public consultation on its Multinational Anti-avoidance law on May 12, 2015:

“In the 2015-16 Budget, the Government announced that it would introduce the tax integrity multinational anti‑avoidance law to stop multinational entities using artificial or contrived arrangements to avoid a taxable presence in Australia.

This exposure draft Bill and associated explanatory material would amend the anti-avoidance rules in Part IVA of the Income Tax Assessment Act 1936, giving effect to that decision.

The measure is intended to target situations in which:

  • a foreign multinational supplies goods or services to Australian customers and books that revenue offshore;
  • the activities of an Australian entity are integral to the Australian’s customer’s decision to purchase the goods or services;
  • the profits from Australian sales are subject to low or no global tax; and
  • one of the principal purposes of the arrangements is to obtain a tax benefit.

Where the measure applies, the Commissioner of Taxation may cancel the Australian tax benefits obtained in connection with the scheme.

This measure will only apply where the non-resident’s annual global revenue is greater than $1 billion.”

See the complete release here.

The Exposure Draft is available here.

The Explanation Material is available here.

Closing date for submissions is set to Tuesday, 9 June 2015.

Robert Robillard, Ph.D., CPA, CGA, Adm.A., MBA, M.Sc. Econ., M.A.P.
Senior Partner, RBRT Inc.
514-742-8086; robertrobillard “at”

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