In the last year we have seen a number of changes to the tax landscape which have the potential to significantly change the way PE sponsors invest in Australia and also how they receive the returns on those investments.
This article highlights the most important of those changes:
- the proposed introduction of the new collective investment vehicle regime (CIV);
- the foreign resident withholding tax regime; and
- the recent Federal Court decision in Millar which confirmed that capitalised PIK interest is subject to withholding tax at the time it is capitalised.
Ready, steady, go — Australia’s new CIV regime out of the starting blocks…
The proposed collective investment vehicle (CIV) regime will finally allow sponsors to move away from trusts and offer corporate and limited partnership fund vehicles.
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