Australia's Hybrid International Tax System: Limited Focus on Tax and Development

Abstract

Australia does not provide tax incentives for investment abroad. However, Australia’s participation exemption regime, which exempts business profits returned to Australia, may be viewed as an incentive to invest offshore. The participation exemption allows a tax exemption for active foreign business income of a corporation resident in Australia and for dividends received by an Australian corporation from foreign subsidiaries actively engaged in foreign business. Buttressed by anti-tax avoidance rules, this regime may provide some incentive for investment in developing countries hoping to attract investment by use of various tax incentives. Australia’s main inbound and outbound investment is with the United States and the United Kingdom; its main outbound investment in developing countries has been primarily in BRICS, Mexico, and the ASEAN regions.