XYZ Pty Ltd (XYZ) is considering the following proposal to provide run to the capital of capital of capital of Singapore Govt (Customer) which allow for be awarded in Nov 2011 and will run for 3 yrs:
The sale 2 items of substantial equipments, requiring modifications and installation in Singapore
Sale of one pieces of equipment in Australia will occur in 2012, after the customer has tested and accepted the equipment (substance abuser acceptance test will take over 6mths in Australia). Customer is answerable for shipping these products to Singapore after purchase
The remaining equipment will be sold in Singapore in 2013 XYZ is responsible for placement shipment
All equipment will be located in Singapore (regardless of where its purchased)
The Customer will pay in instalments outset from vex signing in Nov 2011 and will pay the postulate value in even instalments over the 3 yrs. The instalments are not related to any particular activity.
Training on use of the substantial equipment and the provision of further informative services in respect of the equipment for 3 yrs
The training and some user acceptance training will be conducted in Australia.
XYZ will be required to place 4-6 people in-country to perform the advisory services outlined above.
Question
Please prepare no to a greater extent than 2 pages of draft tax advice for XYZ for the Tax team way to review considering the following:
1.Corporate income tax implications to XYZ
a.consider two Australian and Singapore implications (relevant excerpts of Double Tax Agreement provided)
b. search s23AH of Income Tax Assessment Act 1936 refer to ATO website: http://law.ato.gov.au/atolaw/index.htm
2.GST implications of the contract given the Customer is not Australian, but will leave services performed in Australia
a.Excerpts from GST commentary provided
3.Implications for XYZ employees in Singapore for 3 yrs
a.Consider general principles of taxation to income earned
4.Any other...If you want to progress to a full essay, order it on our website: Orderessay
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