- About
- Services
- Charities and Not-for-Profits
- Audits and Disputes
- Estate Planning and Deceased Estates
- International Tax Issues
- Income Tax
- Structuring, Restructuring and Succession Planning
- WET, Excise and Customs Duty
- Stamp Duty and Land Tax
- Payroll Tax
- Superannuation and SMSFs
- GST and FBT
- CGT and Small Business Concessions
- Contact
At Pengelly & Co Legal, our practitioners have deep expertise with Australia’s international tax rules and cross‑border structuring.
International tax is a highly specialised and constantly evolving field, and the specialised rules can have significant tax implications for individuals and businesses with cross‑border interests.
Whether you are migrating, expanding overseas, investing into or out of Australia, or managing foreign entities and income, you need expert advice to appropriately manage your tax risks and optimise your tax position.
Jessica has highly-regarded expertise in this field, having accrued more than 15 years’ experience across private practice and the Australian Taxation Office, and having published extensively on topical international tax issues.
How we can help
We can advise and assist with matters such as:
Individuals, families & private groups
- Australian tax residency for individual emigrating from, or returning to, Australia
- Foreign trust issues, including section 99B, foreign‑sourced income, controlled foreign trusts and distribution planning
- CGT for non‑residents and temporary residents
- Foreign purchaser duty and state‑based surcharge rules
- Setting up efficient cross-border structures and repatriating funds tax-effectively to Australia
Businesses, funds & multinational Structures
- Cross‑border structuring: establishing or restructuring holding companies, hybrid entities, transparent structures
- Permanent establishment (PE) risks under domestic law and tax treaties, including service, agency and construction PEs
- Controlled foreign company structures
- Advice on withholding taxes and tax registration obligations
What we help with
Tax residency and permanent establishments
Tax residency and permanent establishment advice for individuals and companies
foreign trust issues
Opinions on the taxation of distributions from, or interests in, foreign trusts
Non-resident cgt
Advice for non-residents on liability for CGT, and availability of CGT discount and concessions on sales of property and shares
Cross-border structures
Advice on setting up tax-efficient cross-border structures for business or investment
withholding taxes
Advice on withholding taxes for interest, dividends, royalties and CGT
registrations
Advice on tax registration obligations for foreign-owned businesses
We’re Here When You’re Ready
Whether you have a quick question or need detailed advice, our team is ready to listen and guide you forward.