October 2014 Welcome to the October 2014 edition of TaxTalk Monthly. TaxTalk Monthly Below is a list of topics covered in this edition of TaxTalk, with quick links to help you navigate through the month’s content: Keeping you up to date on the latest Australian and international tax developments International Tax Update .................................... 3 Indirect Tax Update ............................................ 2 Customs & excise update ................................................ 2 OECD's first BEPS recommendations ........................... 3 Software distributor liable to pay withholding tax........ 3 Legislative Update ............................................... 4 Employment Tax Updates ................................... 6 Employment Tax Updates .............................................. 6 Payroll Tax Rebate (TAS) ............................................... 6 Other News ......................................................... 7 Report on subclass 457 visa programme ....................... 7 Federation White Paper: First Issues Paper .................. 7 Customs & excise: new rates for tobacco products ....... 7 Exposure draft Bill proposes changes to the Commissioner’s information gathering and access powers .............................................................................. 7 Development of Northern Australia- Final Report ....... 8 State Taxes Update .............................................. 8 Tasmania: Budget for the 2014-15 financial year.......... 8 Queensland: Payroll tax .................................................. 9 www.pwc.com.au Indirect Tax Update Customs & excise update Korea-Australia Free Trade Agreement Implementation The Customs Amendment (Korea-Australia Free Trade Agreement Implementation) Bill 2014 proposes to amend the Customs Act 1901 to introduce new rules of origin for goods that are imported into Australia from Korea, to implement the Korea-Australia Free Trade Agreement. The amendments will enable goods that satisfy the rules of origin to enter Australia at preferential rates of customs duty. Complementary amendments to give effect to the Agreement will also be made to the Customs Tariff Act 1995 by Customs Tariff Amendment (Korea-Australia Free Trade Agreement Implementation) Bill 2014. The amendments will be operative from the later of 1 December 2014 or the day on which the Agreement comes into force for Australia. Goods which principally functioned as electrical transformers were not entitled to a tariff concession In Becker Vale Pty Ltd and Chief Executive Officer of Customs, the Administrative Appeals Tribunal (AAT) held that certain goods which had the principal function of transforming electricity, were properly classified under heading 8504.34.00 in Schedule 3 of the Customs Tariff Act 1995. Accordingly, the applicant could not benefit from TCO 0918490, as the tariff concession order did not apply to goods classified under that heading. Review of border fees, charges and taxes The Minister for Immigration and Border Protection has announced a review of border fees, charges and taxes and the release of an Industry Consultation Paper. The review will cover current major charging arrangements at the border, including Import Processing and Passenger Movement Charges, certain import related fees and charges recovered by the Department of Agriculture, and visa application charges. However, a number of other fees, charges and taxes will not form part of the review, such as customs duty (including refunds, tariff concessions and drawbacks), GST and other indirect taxes that Customs and Border Protection collects. New rates of excise and customs duty for tobacco products Substituted rates of excise and customs duty were released in respect of certain tobacco products with effect from 1 September 2014. Following recent legislative changes, excise and excise equivalent customs duty on tobacco and tobacco products are indexed based on average weekly ordinary time earnings instead of the Consumer Price Index, with indexation of rates scheduled to occur on 1 March and 1 September. Let’s talk For a deeper discussion of how these issues might affect your business, please contact: Peter Konidaris, National Indirect Taxes leader +61 (3) 8603 1168 peter.konidaris@au.pwc.com Adrian Abbott, Sydney +61 (2) 8266 5140 adrian.abbott@au.pwc.com Gary Dutton, Brisbane +61 (7) 3257 8783 gary.dutton@au.pwc.com Suzi Russell, Sydney +61 (2) 8266 1057 suzi.russell@au.pwc.com Ross Thorpe, Perth & Melbourne +61 (8) 9238 3117 ross.thorpe@au.pwc.com Michelle Tremain, Perth +61 (8) 9238 3403 michelle.tremain@au.pwc.com PwC Page 2 International Tax Update OECD's first BEPS recommendations The Organisation for Economic Co-operation and Development (OECD) has released its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises, under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. The recommendations address the following seven action points (BEPS reports) in the OECD BEPS Action Plan: Addressing the tax challenges of the digital tax economy Neutralising the effects of hybrid mismatch arrangements Preventing the granting of treaty benefits in inappropriate circumstances Countering harmful tax practices more effectively Guidance on transfer pricing aspects of intangibles Guidance on transfer pricing documentation, and Country-by-country reporting. An Explanatory Statement provides an overview of the seven BEPS reports and also describes the status of the reports in the context of the overall Project, including remaining technical issues and potential interaction with the remaining Project work to be carried out. It also outlines the next steps for the BEPS Project work. Participating countries have agreed on the feasibility of a multilateral instrument to streamline implementation of anti-BEPS measures and in January next year, will consider a draft mandate for an international conference so that a multilateral instrument could be negotiated. For further information see the PwC Tax Policy Bulletin. Software distributor liable to pay withholding tax In Task Technology Pty Ltd v Commissioner of Taxation [2014] FCAFC 113, the Full Federal Court dismissed the appeal by Task Technology Pty Ltd (Task) against the decision at first instance (see Task Technology Pty Ltd v Commissioner of Taxation [2014] FCA 38), where Justice Davies held that the payments made by Task to a Canadian resident company (CaseWare) were PwC ‘royalties’ for the purposes of the Convention between Australia and Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (Canberra, 21 May 1980) (the Canadian Treaty). Task was the distributor in Australia of software developed by CaseWare. As found by Justice Davies, the software is a computer program consisting of source code, which causes accounting and financial data input into various templates used with the software to be output automatically in the form of financial and accounting reports. The template is used in conjunction with the software to enable information to be output in a form appropriate for the end user. Task was licensed by CaseWare to market and distribute the software pursuant to ‘end user licences’, and to make copies of the software for distribution. It was also licensed to develop and supply templates for use with the software pursuant to ‘application template licences’. Task paid annual fees to CaseWare under its licensing arrangements with CaseWare, and in the period under consideration, the fees paid included a percentage of the software and template license fees that TFask charged its customers. The Commissioner’s position was that the amounts paid to CaseWare were ‘royalties’ derived by a nonresident, and since Task had failed to withhold tax from the payments, Task was liable to penalty under section 16-30 of Schedule 1 to the Taxation Administration Act 1953. Task’s position was that the payments were not ‘royalties’, and that accordingly it was not liable to deduct tax from the payments. Task sought declarations from the Court to that effect. It was common ground at trial that the payments were ‘royalties’ unless covered by Article 12(7) of the Canadian Treaty. That Article provided that, for the purposes of the Treaty, ‘royalties’ did not include “payments or credits made as consideration for the supply of, or the right to use, source code in a computer software program, provided that the right to use the source code is limited to such use as is necessary to enable effective operation of the program by the user”. In dismissing Task’s appeal, the Full Court found that under the licence agreement with CaseWare, Task was not supplied with the source code, nor was it granted the right to use the source code. On this point the Court dismissed Task’s argument Page 3 that a right to use the computer software program constituted a right to use source code in that program for the purposes of Article 12(7) of the Canadian treaty. Since the payments made by Task were not in respect of the supply of or right to use the source code, the proviso in Article 12(7) did not apply and the payments were ‘royalties’. This decision highlights the need to carefully consider cross border licence agreements to determine what payments made under the agreement relate to. Since tax treaties entered into by Australia with foreign jurisdictions often vary, the terms of the particular treaty then need to be reviewed to determine whether the payments made will be ‘royalties’, with resulting obligations to pay tax under the Australian tax system. For further information contact Eddy Moussa on (02) 8266 9156. Let’s talk For a deeper discussion of how these issues might affect your business, please contact: Peter Collins, Melbourne +61 (3) 8603 6247 peter.collins@au.pwc.com Christian Holle, Sydney +61 (2) 8266 5697 christian.holle@au.pwc.com James Strong, Melbourne +61 (3) 8603 6599 james.r.strong@au.pwc.com Legislative Update percentage points. The higher (refundable) rate of the tax offset will be reduced from 45 per cent to 43.5 per cent and the lower (nonrefundable) rate of the tax offset will be reduced from 40 per cent to 38.5 per cent. The reduction in the tax offset rates is consistent with the Government’s commitment to cut the company tax rate from 1 July 2015 by maintaining the relative value of the offsets. These amendments will apply to assessments for income years commencing on or after 1 July 2014 Revenue measures introduced into the Commonwealth Parliament include: Customs Amendment (Korea-Australia Free Trade Agreement Implementation) Bill 2014 and the Customs Tariff Amendment (Korea-Australia Free Trade Agreement Implementation) Bill 2014 - introduced into the House of Representatives on 4 September 2014. These Bills propose to amend the Customs Act 1901 and the Customs Tariff Act 1995 to implement the Korea-Australia Free Trade Agreement Tax and Superannuation Laws Amendment (2014 Measures No 5) Bill 2014, which was introduced into the House of Representatives on 4 September 2014, proposes a number amendments to the Income Tax Assessment Act 1997 (ITAA 1997) and to the Taxation Administration Act 1953 (TAA 1953). The Bill includes measures to: abolish the mature age worker tax offset in respect of assessments for the 2014-15 income year and later income years abolish the seafarer tax offset in respect of assessments for the 2015-16 income year and later income years make minor consequential changes to the ITAA 1997 and to the Shipping Reform (Tax Incentives) Act 2012 to remove references to the seafarer tax offset amend the ITAA 1997 to reduce the rates of the tax offset available under the research and development (R&D) tax incentive by 1.5 PwC amend the ITAA 1997 to update the list of specifically listed deductible gift recipients (DGRs) through adding: The Minderoo Foundation Trust (for gifts after 1 January 2014), Australian Schools Plus Ltd (for gifts made on or after 1 April 2014) and the East African Fund (for gifts made on or after 1 July 2014). Minerals Resource Rent Tax Repeal and Other Measures Bill 2014 - introduced into the House of Representatives on 1 September 2014 and subsequently passed by the Senate with amendments, received Royal Assent on 2 September 2014, was enacted as the Minerals Resource Rent Tax Repeal and Other Measures Act 2014 (the Act). On 18 September 2014, the Governor General, by Proclamation, fixed the commencement date of Schedule 1 to 5 of the Act as 30 September 2014. In summary: Schedule 1 repeals the Mineral Resource Rent Tax (MRRT) such that the MRRT no longer Page 4 applies after 30 September 2014. Transitional rules apply to ensure that the MRRT year ends on 30 September 2014 for all taxpayers, and to adjust various thresholds and other rules where the repeal means that taxpayers will have a short final MRRT year. Schedule 2 repeals the ‘loss carry back’ measure in the ITAA 1997 which allowed companies to utilise a tax loss for a current income year by way of an offset having regard to tax paid in either of the two preceding income years in certain circumstances. The repeal has effect from the start of the income year before the income year in which Schedule 2 commences. For companies with a 30 June tax year, this means that the repeal retrospectively applies from the start of the 2013-14 income year. Those taxpayers who already claimed the loss carry-back offset for the 2013-14 income year can now expect to receive an amended assessment from the ATO to disallow the claim and will be required to repay the full amount of the previously refunded offset, with no penalties or interest. Schedules 3 and 4 amend the capital allowance concessions for small business entities (SBE) in the ITAA 1997 so that: 1. 2. 3. 4. The optional immediate write off of the cost of a depreciating asset (or an improvement to an existing depreciating asset) will only apply for depreciating assets costing less than $1,000 (instead of $6,500), and in all cases, the deduction will be limited to the ‘business use percentage’ Depreciating assets that cost $1,000 or more will be able to be allocated to the ‘general small business pool’, which will be depreciated at the rate of 15 per cent in the year of allocation, and 30 per cent in later years The balance of a ‘general small business pool’ will be fully deductible only where it is less than $1,000 (instead of $6,500) at the end of an income year The special rule for claiming an ‘upfront’ $5,000 capital allowance deduction in respect of motor vehicles costing more than $6,500 is repealed. This will mean that motor vehicles become subject to the same rules for claiming capital allowance deductions that apply to other depreciating assets. These amendments apply from 1 January of the income year before the income year in which Schedules 3 and 4 commence. As these Schedules commence on 30 September 2014, the amendments apply from 1 January 2014 for 30 June balancers. PwC Schedule 5 repeals special deductions for expenditure incurred in relation to geothermal energy exploration and prospecting. The repeal has effect from the start of the income year in which Schedule 5 commences. As this Schedule commences on 30 September 2014, the repeal applies from 1 July 2014 for 30 June balancers. Schedule 6 amends the timetable for increasing the superannuation guarantee (SG) charge percentage to 12 per cent by freezing the SG rate at 9.5 per cent for financial years commencing 1 July 2014 up to and including 2020-21. The SG charge percentage will then increase by half a percentage point each year, until it reaches 12 per cent for years starting on or after 1 July 2025. Schedule 7 abolishes the low income superannuation contribution for concessional contributions made for the 2017-18 financial year and later financial years. Schedule 8 abolishes the income support bonus from 31 December 2016 and makes minor technical and consequential amendments. Schedule 9 abolishes the Schoolkids Bonus from 31 December 2016, and introduces an income test for payments of the bonus between Royal Assent of the Act (5 September 2014) and 31 December 2016. MRRT legislative instruments, registered on 24 September 2014, have the effect of exempting certain MRRT entities from having to lodge an MRRT return. Since the MRRT does not have any ongoing operation after 30 September 2014 (as mentioned earlier), to simplify administrative requirements, the Commissioner of Taxation will not require the lodgment of an MRRT return for those entities covered by the following: Exemption for lodgment of 2014 or 2015 MRRT Returns – Large volume non-payers’ Instrument (No 1) 2014 – broadly applicable to an entity that did not pay an MRRT instalment in respect of any instalment quarter during the relevant MRRT year, and is an entity that the Commissioner has determined, in writing, to be a large volume non paying entity for that MRRT year, and Exemption for lodgment of 2013, 2014 or 2015 MRRT Returns – Low volume non-payers’ Instrument (No 1) 2014 – broadly applicable to an entity that did not pay an MRRT instalment in respect of any instalment quarter during the relevant MRRT year, and was not a ‘major producer’ as defined by the instrument for any of the 2013, 2014 or 2015 MRRT years. Page 5 Let’s talk For a deeper discussion of how these issues might affect your business, please contact: Tom Seymour, Managing Partner +61 (7) 3257 8623 tom.seymour@au.pwc.com Warren Dick, Sydney +61 (2) 8266 2935 warren.dick@au.pwc.com David Lewis, Perth +61 (8) 9238 3336 david.r.lewis@au.pwc.com Scott Bryant, Adelaide +61 (8) 8228 7450 scott.a.bryant@au.pwc.com David Ireland, Sydney +61 (2) 8266 2883 david.ireland@au.pwc.com Julian Myers, Brisbane +61 (7) 3257 8722 julian.myers@au.pwc.com Adam Davis, Melbourne +61 (3) 8603 3022 adam.davis@au.pwc.com Anthony Klein, Melbourne +61 (3) 8603 6829 anthony.klein@au.pwc.com Murray Evans, Newcastle +61 (2) 4925 2239 murray.evans@au.pwc.com Employment Tax Updates Employment Tax Updates Following the decision in Conrad Linings Pty Limited v Chief Commissioner of State Revenue [2014] NSWSC 1020 last month, the issue of degrouping was again brought before the Civil and Administrative Tribunal New South Wales in Boston Sales and Marketing Pty Limited v Chief Commissioner of State Revenue [2014] NSWSCATAD 139 and Lombard Farms Pty Ltd v Chief Commissioner of State Revenue [2014] NSWSCATAD 132. In both cases, the Tribunal affirmed the decision of the Chief Commissioner not to exercise his discretion to de-group certain entities under section 79 of the Payroll Tax Act 2007. The Tribunal found that the taxpayers had not adequately discharged their onus to prove that the grouped businesses were carried on independently of each other and were not connected with the carrying on of a business by another group member. These cases serve as yet another reminder that the onus of proof rests with the taxpayer in respect of de-grouping and they should ensure sufficient evidence is maintained to support their tax position. Payroll Tax Rebate (TAS) The Tasmanian Government has introduced Employee Incentive Scheme Payroll tax Rebate 4 to provide employers with payroll tax rebates equivalent to the payroll tax levied on wages paid to eligible new employees between 30 June 2014 and 30 June 2015. The scheme is an incentive for creating additional positions in Tasmania between 30 June 2014 and 30 June 2015, and maintaining them through to 30 June 2016. The scheme provides a payroll tax rebate of up to two years, and the Government is expecting that the rebate will generate approximately 600 jobs. Let’s talk For a deeper discussion of how the above employment tax issues might affect your business, please contact: Greg Kent, Melbourne +61 (3) 8603 3149 greg.kent@au.pwc.com Rohan Geddes, Sydney +61 (2) 8266 7261 rohan.geddes@au.pwc.com Maria Ravese, Adelaide +61 (8) 8218 7494 maria.a.ravese@au.pwc.com Paula Shannon, Brisbane +61 (7) 3257 5751 paula.shannon@au.pwc.com PwC Page 6 Other News Report on subclass 457 visa programme On 10 September 2014 the Government announced the release of the review - An Independent Review into Integrity in the Subclass 457 Programme. Some recommendations in the review concern the role of the Australian Taxation Office (ATO) including a recommendation that there be greater collaboration between the Department of Human Services and the ATO to uphold integrity within the 457 Programme and to minimise the burden on employers. This may include the sharing of information for compliance purposes. In releasing the review for public consumption, the Government in its media release said that it “will announce a detailed response to the report shortly”. Federation White Paper: First Issues Paper On 12 September 2014, the Prime Minister announced the release of the First Issues Paper for the Reform of the Federation White Paper. The Federation White Paper will be closely aligned with the White Paper on the Reform of Australia’s Tax System. A Federation Green Paper will be published in the first half of 2015 before the Federation White Paper which is planned to be finalised towards the end of 2015. One of the issues raised for consideration in the Issues Paper is the ‘vertical fiscal imbalance’ (VFI) that results from the Federation in that the Commonwealth Government raises more revenue than it needs to fund its own-purpose expenditure, and the sub-national governments (State, Territory and Local Governments) raise less revenue than they need to fund their expenditures. The consequence is that the Commonwealth Government finances, through transfers to the sub-national governments, a proportion of those Governments’ expenditures. The Issues Paper states that “in Australia, VFI has grown largely as a result of High Court decisions on the interpretation of the Constitution in relation to taxation matters, and also because States have passed up opportunities to take back a greater role in levying income tax”. According to the Issues Paper, the Commonwealth raises 82 per cent of all tax revenue in Australia whereas in Canada, the national government raises only 45 per cent of all tax revenue. The Paper asks the question: PwC What are the best ways to address the situation whereby there is a mismatch between what the Commonwealth and the States and Territories each spend on the one hand, and what they each raise in revenue on the other? The Issues Paper does not specify details of the public engagement process, however it states that these will be released shortly on the website: www.federation.dpmc.gov.au. Customs & excise: new rates for tobacco products Following recent legislative changes, excise and excise equivalent customs duty on tobacco and tobacco products are indexed based on average weekly ordinary time earnings instead of the Consumer Price Index, with indexation of rates scheduled to occur on 1 March and 1 September of each year. On 1 September 2014 the relevant administering Authority formally published the Customs and Excise substituted rates of excise and duty in respect of these products. The rates are effective from 1 September 2014. Exposure draft Bill proposes changes to the Commissioner’s information gathering and access powers On 27 August 2014, the Commonwealth Treasury released for public consultation, an exposure draft Bill and Explanatory Material which includes provisions to: consolidate duplicated taxation administration provisions contained in various taxation statutes into a single set of provisions in Schedule 1 to the Taxation Administration Act 1953 (TAA 1953) repeal spent or redundant taxation laws, and move longstanding regulations into the ‘primary law’. In relation to income tax, one of the proposed changes is the repeal of sections 263 and 264 of the Income Tax Assessment Act 1936 (ITAA 1936). These provisions currently give to the Commissioner, information gathering powers and access powers for the purposes of the income tax law. It is proposed that these powers will be consolidated into provisions in Division 353 of Schedule 1 to the TAA 1953 which will be expanded so that they will apply to any ‘taxation law’, being in effect any Commonwealth law in respect of which the Commissioner of Taxation has powers of Page 7 administration. Although the proposed consolidated provisions are in many ways consistent with the Commissioner's existing powers, the scope of what the Commissioner can do after accessing a site is to be expanded. For further information on this proposed change or on the Commissioner’s information gathering powers generally, contact Judy Sullivan on (02) 8266 3216. Development of Northern AustraliaFinal Report On 4 September 2014 the Inquiry into the Development of Northern Australia- Final Report was tabled in the Commonwealth Parliament. The Report, which was prepared to assist the Government in formulating its policy for the future development of Northern Australia, features the following tax-related recommendations to the Government: explore reforms to the taxation system to better promote investment and development in Northern Australia (including the possibility of measures targeting the resources and agriculture sectors and the establishment of special economic zones) investigate the equity of the current application of the Zone Tax Offset arrangements, and review of the taxation treatment of fly-in, flyout (FIFO) work arrangements including a review of access to the Fringe Benefits Tax exemptions for FIFO work arrangements, ‘upfront’ deductibility of certain expenses, and putting residential housing on a level playing field with transient worker accommodation in terms of. The Government is expected to respond to the recommendations via its Tax Reform White Paper. Let’s talk For a deeper discussion of how these issues might affect your business, please contact: Tom Seymour, Managing Partner +61 (7) 3257 8623 tom.seymour@au.pwc.com Warren Dick, Sydney +61 (2) 8266 2935 warren.dick@au.pwc.com David Lewis, Perth +61 (8) 9238 3336 david.r.lewis@au.pwc.com Scott Bryant, Adelaide +61 (8) 8218 7450 scott.a.bryant@au.pwc.com David Ireland, Sydney +61 (2) 8266 2883 david.ireland@au.pwc.com Julian Myers, Brisbane +61 (7) 3257 8711 julian.myers@au.pwc.com Adam Davis, Melbourne +61 (3) 8603 3022 adam.davis@au.pwc.com Anthony Klein, Melbourne +61 (3) 8603 6829 anthony.klein@au.pwc.com Murray Evans, Newcastle +61 (2) 4925 1139 murray.evans@au.pwc.com State Taxes Update Tasmania: Budget for the 2014-15 financial year Budget Estimate. Expected growth in the Tasmanian economy for 2014-15 is 1.5 per cent. The Tasmanian State Budget for the 2014-15 financial year was delivered on 28 August 2014 by the Tasmanian Treasurer. State taxes generally The Government has forecast a deficit of $285 million for 2014–15, decreasing to a deficit of $118 million by 2017–18. The Government anticipates that a return to operating surpluses will be achieved in approximately six years. Taxation revenues have been revised up to $983.2 million, an increase of 4.6 per cent above the 2013–14 PwC The Government has not introduced any new taxes or increased the rate of any existing taxes in the Budget or over the Forward Estimates. Notably, total revenue is only estimated to grow at an average annual rate of 1.9 per cent over the Budget and Forward Estimates, which is below the long run trend of 4.4 per cent per annum. State taxation revenue, however, is forecast to grow at an average rate of 2.9 per cent from 2014–15. Page 8 Payroll tax The Government has introduced its fourth Employee Incentive Scheme Payroll Tax Rebate. This measure will provide private sector employers who create additional, eligible positions in Tasmania from 30 June 2014 to 30 June 2015 with a payroll tax rebate for up to two years. Motor tax The Government will reduce the tax rate on light vehicles over two years, commencing 1 July 2017, back to pre 1 October 2012 levels (adjusted for inflation). First Home Builders Boost The First Home Builders Boost scheme will no longer expire on 31 December 2014. The Government has decided to extend the arrangements for six months from 1 January 2015 to 30 June 2015 at a level of $20,000 and then continue the scheme at $10,000 from 1 July 2015 on an ongoing basis. $1.6 billion to be spent over the Budget and Forward Estimates. In 2014–15, the planned investment in infrastructure is $391.1 million and includes: $30.8 million for schools and education infrastructure $100.3 million for hospitals and health infrastructure $43.9 million for housing;$191.6 million for roads infrastructure $8.6 million for prisons, and $12.6 million for tourism, recreation and culture. Queensland: Payroll tax On 5 September 2014, the Queensland Treasurer announced that from next year, businesses with an annual payroll tax liability of less than $20,000 will now only be required to lodge payroll tax returns twice a year, instead of every month. Key capital expenditures A focus of the 2014–15 Budget is spending on major infrastructure projects, with an estimated Let’s talk For a deeper discussion of how these issues might affect your business, please contact: Barry Diamond, Melbourne +61 (3) 8603 1118 barry.diamond@au.pwc.com Costa Koutsis, Sydney +61 (2) 8266 3981 costa.koutsis@au.pwc.com © 2014 PricewaterhouseCoopers. All rights reserved. In this document, “PwC” refers to PricewaterhouseCoopers a partnership formed in Australia, which is a member firm of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity. This publication is a general summary. It is not legal or tax advice. Readers should not act on the basis of this publication before obtaining professional advice. PricewaterhouseCoopers is not licensed to provide financial product advice under the Corporations Act 2001 Cth). Taxation is only one of the matters that you need to consider when making a decision on a financial product. You should consider taking advice from the holder of an Australian Financial Services License before making a decision on a financial product. Liability limited by a scheme approved under Professional Standards Legislation. PwC Page 9