Tax Bites: Insights on tax developments
We explore the latest tax developments.
In this podcast series, our tax team delve into the latest developments that are likely to affect businesses functioning or actively trading.
Tax Bites: Insights on tax developments
Tax Bites EP15: Understanding Section 899: US retaliatory tax measures and the impact on Australian taxpayers
In this episode of the Herbert Smith Freehills Kramer Tax Bites podcast, hosts Toby Eggleston and Professor Graham Cooper discuss the significant implications of the proposed Section 899 under President Trump's 'One Big, Beautiful Bill' Act. They delve into how these retaliatory taxes imposed by the US aim to counteract what are perceived to be unfair or discriminatory foreign taxes, particularly affecting Australian companies. The discussion covers the legislative background, specific unfair taxes such as undertaxed profits rules, digital services taxes, and diverted profits taxes. They also explore the potential consequences for Australian taxpayers, the Australian government's actions, and the broader impact on the international tax regime.
00:10 Introduction and Greetings
00:31 Overview of Section 899 and Its Implications
00:56 Background and Legislative Process
01:52 Impact on Australian Firms and Government
05:26 Unfair Foreign Taxes Defined
10:29 Potential Triggers and Affected Taxes
11:53 Impact on Australian Taxpayers and Government
16:52 Modifications to BEAT Rules
20:50 Treaty Interactions and Future Implications
23:23 Conclusion and Final Thoughts