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Arthur T Knackerbracket has found the following story:

The Australian Taxation Office (ATO) has warned that the nation's attempts at imposing a "Google Tax" are already being circumvented, and suggested big accountancy firms have found a way around efforts to stymie multinational tax avoidance.

Australia's Google Tax, formally known as the Multinational Anti-Avoidance Law (MAAL), is modelled on the UK's and imposes penalties on companies that move money offshore for the sole purpose of legally-but-cynically avoiding tax.

[...] Indeed the Office says it's just found a new [technique] it considers "artificial and contrived," as it "involves interposing an entity described as a partnership between the foreign entity originally making supplies to Australian customers, and the Australian customers."

"The partnership has one resident corporate partner with a minority interest in the partnership, therefore purporting to characterise the partnership as an 'Australian entity' for the purposes of the MAAL." But nothing changes in the business' actual operations, and the ATO says: "The arrangements have little, if any, commercial basis."

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