Who Is Affected?
The Treasury has released its Stapled Structures Integrity Package, which will impact foreign investors with stapled structure arrangements, as well as foreign pension and sovereign wealth funds and investors in agricultural trusts. There will be less impact on domestic investors and stapled structures will remain a tax effective way for them to hold property and infrastructure assets.
Why Are the Changes Being Made?
The Treasury is concerned with businesses characterizing trading income as passive income in order to receive more favourable tax rates and the concessions currently available to foreign pension and sovereign wealth funds.