Major Projects

Tax

Tax » Major Projects

All levels of government remain focused on the infrastructure sector and the delivery of major projects as a driver of increased productivity and economic growth. As part of the 2014-15 Budget, the Federal Government announced the Asset Recycling Initiative designed to encourage the States and Territories to privatise assets and use the proceeds to invest in new significant infrastructure projects.

Although there remains a long list of significant projects, in the current economic environment governments need to prioritise which projects to proceed with and give close attention to the value proposition on such projects. Likewise, the private sector needs to be innovative in demonstrating how value can be delivered.

Our tax team has advised both the public and private sector on some of the largest infrastructure projects undertaken in Australia over recent years, including the Gold Coast Rapid Transit Project, Victorian Desalination Project, Mundaring Waste Treatment Plant, Airport Link and the Queensland, Victorian and South Australian Schools PPPs. Whether acting for clients bidding for a project or acting for government evaluating those bids, the tax efficiency of a project structure will be a critical part of the value proposition. Corrs has developed and evaluated common structures for implementing PPP projects such as stapled, securitised and prepaid structures and variations to them. Corrs’ experience gives us a unique insight into those structures and a thorough understanding of the government’s approach to tax risk.

By appointing Corrs as tax adviser to a project, our clients have benefitted from seamless integration with the broader Corrs major projects team, ensuring that our advice covers all relevant legal issues including tax and the delivery of timely responses regarding the tax implications of developments as a project progresses.

Corrs involvement on the tax committees of Infrastructure Partnership Australia and the Law Council of Australia ensure that we contribute to the tax policy debates impacting the infrastructure sector and structures commonly adopted for implementing infrastructure projects.

Our Experience

Gold Coast Rapid Transit

The Gold Coast Rapid Transit Project, a light rail linking key centres on the Gold Coast, is a landmark infrastructure project in Queensland. Corrs was involved from the outset of the project and advised the Queensland Government on all tax related issues associated with the project including income tax, GST, stamp duty, land tax and council rates.

The team worked closely with Corrs’ projects lawyers to help Government develop the required level of certainty needed in this critical area of the project.

More

Our Thinking

Australia's Tax Treaty Negotiation Program needs an Asian pivot

Refocusing Australia’s bilateral tax treaty network towards Asia should be a priority for the Abbott government.

More

Federal Budget 2014-15: The Government delivers on austerity but not genuine tax reform

Federal Treasurer, the Hon. Joe Hockey MP, has delivered his keenly anticipated first budget. So what are the most significant measures that will impact the business bottom line?

More

Curbing the flight of the phoenix - New solutions are needed to address insolvency in the construction industry

Building company insolvencies are rife and state governments must act.

More

What does real tax reform look like?

Australia faces tough decisions it can’t keep putting off.

More

Are there ‘real changes’ ahead for Australia’s mining sector?

Tony Abbott has declared Australia is ‘open for business’ but will the Coalition’s promises translate to real change?

More

Infrastructure early stage tax losses - Welcome reform but issues remain

The draft legislation on tax loss incentives for infrastructure projects is welcome, but gaps remain.

More

Federal Budget 2013-14: A tough one for business, especially multinational business

What are the most significant tax measures that will impact the business bottom line?

More

Australia turns up the heat on large and multinational taxpayers

The government’s announcement that it wants greater transparency around the tax activities of large businesses and multinationals reveals a suspicion that it’s missing out on tax revenue it ought to be getting.

More

Transfer pricing and Part IVA: Taxpayers are winning the battles but losing the war

The Commissioner of Taxation has successfully lobbied for reforms to the transfer pricing regime and Part IVA. Can taxpayers fight back?

More

The good, the bad and the ugly: Reflecting on transfer pricing developments in 2012

Australia’s transfer pricing landscape has been transformed. While some changes are positive, other aspects are positively alarming.

More

A refocused tax treaty network is key to achieving the Asian Century vision

Australia must urgently refocus its tax treaty network towards Asia if it is to compete with Hong Kong and Singapore as a regional investment hub.

More

Is Victoria’s landholder duty a new tax on development in that state?

Victoria’s new landholder duty regime will squeeze property developers’ profits and may deter new investment in the state.

More

Are the retrospective transfer pricing measures unconstitutional?

The Government’s willingness to introduce tax laws with retrospective effect creates fertile ground for a constitutional challenge.

More

A lower company tax rate. At what cost?

The Government wants to cut the corporate tax rate. But tough decisions must be made and not everyone will win.

More

Federal Budget 2012-13: The major business tax measures

Business won’t be thrilled with the 2012-13 Budget, but should be relieved that other changes floated in the lead up ended up on the cutting room floor.

More

The Minerals Resource Rent Tax - All systems go?

Subject to the possibility of a successful High Court challenge, and perhaps the outside chance of a Federal Election being called, Australia will have a new tax on iron ore and coal mining with effect from 1 July 2012.

More

The Minerals Resource Rent Tax - One step closer?

The Minerals Resource Rent Tax is one step closer to becoming a reality with the introduction of the Minerals Resource Rent Tax Bill 2011 into Parliament. Now is the time for MRRT taxpayers to prepare for its introduction.

More

Infrastructure needs more than tax incentives

In the 2011 Federal Budget, the Government promised new incentives to encourage investment in infrastructure. While further clarity on the incentives is welcome, this alone will not fix the nation’s infrastructure investment woes.

More

The Tax Forum - Worth the wait?

Will this week’s Tax Forum put the wheels back on the tax reform cart? Jonathon Leek considers the Government’s record on tax reform and the likelihood of real and effective reform.

More

Further tax complexities for deferred farm-out arrangements

The Australian Taxation Office has now released a second draft ruling on farm-out arrangements which highlights additional tax complexities when the acquisition of an interest by a farmee in a mining tenement is deferred.

More

Farm-out arrangements in ATO’s sights

A new draft tax ruling signals potential income tax and GST consequences for parties to immediate transfer farm-out arrangements.

More

Our Experts

Rhys Jewell.jpg

Rhys Jewell

Partner Location Melbourne Profile

Our Experience

Gold Coast Rapid Transit

The Gold Coast Rapid Transit Project, a light rail linking key centres on the Gold Coast, is a landmark infrastructure project in Queensland. Corrs was involved from the outset of the project and advised the Queensland Government on all tax related issues associated with the project including income tax, GST, stamp duty, land tax and council rates.

The team worked closely with Corrs’ projects lawyers to help Government develop the required level of certainty needed in this critical area of the project.

Our Thinking

Australia's Tax Treaty Negotiation Program needs an Asian pivot

Refocusing Australia’s bilateral tax treaty network towards Asia should be a priority for the Abbott government.

Federal Budget 2014-15: The Government delivers on austerity but not genuine tax reform

Federal Treasurer, the Hon. Joe Hockey MP, has delivered his keenly anticipated first budget. So what are the most significant measures that will impact the business bottom line?

Curbing the flight of the phoenix - New solutions are needed to address insolvency in the construction industry

Building company insolvencies are rife and state governments must act.

What does real tax reform look like?

Australia faces tough decisions it can’t keep putting off.

Are there ‘real changes’ ahead for Australia’s mining sector?

Tony Abbott has declared Australia is ‘open for business’ but will the Coalition’s promises translate to real change?

Infrastructure early stage tax losses - Welcome reform but issues remain

The draft legislation on tax loss incentives for infrastructure projects is welcome, but gaps remain.

Federal Budget 2013-14: A tough one for business, especially multinational business

What are the most significant tax measures that will impact the business bottom line?

Australia turns up the heat on large and multinational taxpayers

The government’s announcement that it wants greater transparency around the tax activities of large businesses and multinationals reveals a suspicion that it’s missing out on tax revenue it ought to be getting.

Transfer pricing and Part IVA: Taxpayers are winning the battles but losing the war

The Commissioner of Taxation has successfully lobbied for reforms to the transfer pricing regime and Part IVA. Can taxpayers fight back?

The good, the bad and the ugly: Reflecting on transfer pricing developments in 2012

Australia’s transfer pricing landscape has been transformed. While some changes are positive, other aspects are positively alarming.

A refocused tax treaty network is key to achieving the Asian Century vision

Australia must urgently refocus its tax treaty network towards Asia if it is to compete with Hong Kong and Singapore as a regional investment hub.

Is Victoria’s landholder duty a new tax on development in that state?

Victoria’s new landholder duty regime will squeeze property developers’ profits and may deter new investment in the state.

Are the retrospective transfer pricing measures unconstitutional?

The Government’s willingness to introduce tax laws with retrospective effect creates fertile ground for a constitutional challenge.

A lower company tax rate. At what cost?

The Government wants to cut the corporate tax rate. But tough decisions must be made and not everyone will win.

Federal Budget 2012-13: The major business tax measures

Business won’t be thrilled with the 2012-13 Budget, but should be relieved that other changes floated in the lead up ended up on the cutting room floor.

The Minerals Resource Rent Tax - All systems go?

Subject to the possibility of a successful High Court challenge, and perhaps the outside chance of a Federal Election being called, Australia will have a new tax on iron ore and coal mining with effect from 1 July 2012.

The Minerals Resource Rent Tax - One step closer?

The Minerals Resource Rent Tax is one step closer to becoming a reality with the introduction of the Minerals Resource Rent Tax Bill 2011 into Parliament. Now is the time for MRRT taxpayers to prepare for its introduction.

Infrastructure needs more than tax incentives

In the 2011 Federal Budget, the Government promised new incentives to encourage investment in infrastructure. While further clarity on the incentives is welcome, this alone will not fix the nation’s infrastructure investment woes.

The Tax Forum - Worth the wait?

Will this week’s Tax Forum put the wheels back on the tax reform cart? Jonathon Leek considers the Government’s record on tax reform and the likelihood of real and effective reform.

Further tax complexities for deferred farm-out arrangements

The Australian Taxation Office has now released a second draft ruling on farm-out arrangements which highlights additional tax complexities when the acquisition of an interest by a farmee in a mining tenement is deferred.

Farm-out arrangements in ATO’s sights

A new draft tax ruling signals potential income tax and GST consequences for parties to immediate transfer farm-out arrangements.

Our Experts

Rhys Jewell.jpg

Rhys Jewell

Partner Melbourne +61 3 9672 3455