It has been well over two decades since Oxley Secondary College, south west of the Brisbane CBD, closed its doors. The vast block of land sat perfectly between Oxley Station and Canossa Private Hospital, which made it ripe for a new residential-led masterplan.

Just over four years ago, <a href="https://www.apartments.com.au/developers/honeycombes-property-group">Honeycombes Property Group</a> Founder Peter Honeycombe expressed his interest in a 9,644 sqm section of the broader Songbird Oxley masterplan, where a new townhouse neighbourhood would take shape.

Having spent the last three decades in development, working on major suburb-shaping projects like Ferny Gr​ove Central and Coor​paroo Square, Honeycombe knew his first step.

[smartcode_project:default project_id=149443 project_image_fid=5238]

“While it’s not a requirement, we always hold public forums before we even lodge our development applications,” Honeycombe says. “We want to know what type of housing resonates the most with the local community, because ultimately they are the most likely to call it home.”

At <a href="https://www.apartments.com.au/developments/oxley-qld-4075">Oxley</a>, Honeycombes held four forums, which he attended personally to speak to the community. For Ferny Gr​ove Central, he held nine.

“It’s about creating something that belongs to the community. The site was ripe for regeneration, and the feedback we ascertained from the community was that they wanted amenities that could bring people together again.”

[smartcode_project:default project_id=149443 project_image_fid=5241]

Significant amenity is already established in the wider masterplan, like a childcare centre and a cafe, which are ideally located directly across from the <a href="https://www.apartments.com.au/new-townhouses/songbird-terraces-oxley-10-honeyeater-circuit-oxley-qld-4075">Songbird Terraces</a> development.

The feedback also signalled a preference for townhouses over apartments. A townhouse product would lend itself to young families who could utilise the nearby childcare centre, downsizers, and multi-generation families.

There are just 34 three and four-bedroom townhouses that make up Songbird Terraces, each with private courtyards, two car spaces, and access to shared outdoor spaces that include a heated swimming pool with an adjoining alfresco terrace.

[smartcode_project:default project_id=149443 project_image_fid=5242]

Honeycombe sees townhouses as an under-appreciated asset class, offering a middle ground between apartments and detached houses.

“Some people want the low maintenance and shared amenities of apartments. Others want the size of a house but without the upkeep of a large backyard. Townhouse communities like Songbird bridge that gap,” he said.

Songbird Terraces’ position within the larger Songbird Oxley masterplan reinforces its family and lifestyle focus. With a childcare centre opposite, a nursing home next door, and parks on two sides, the neighbourhood is positioned as a multigenerational community hub.

[smartcode_project:default project_id=149443 project_image_fid=5237]

Honeycombes, working with builder Clearcon, expects the retail component of the masterplan to be roofed by mid-next year, with the residential component nearing topping out around the same time.

For Honeycombe, new development is very much a journey, and a two-way street between developer and the local community.

“I think it can be difficult for prospective home buyers to trust developers a lot of the time, but the vast majority spend years on a development. We’ve spent four years getting to this stage of launching the project, and it will be another two years building it. Ferny Gr​ove took 12 years and Coorp​aroo took 11. These projects aren’t quick in-and-out ventures. We’re in it for the long haul, and that’s why the community has to be at the centre of it.”

[smartcode_project_cta:default project_id=149443]

Joel Robinson

Honeycombes Property Group takes community-first approach at Songbird Terraces in Oxley

International developer <a href="https://www.apartments.com.au/developers/mrcb">MRCB</a>&nbsp;has launched its $200 million <a href="https://www.apartments.com.au/new-apartments/maris-southport-20-queen-street-southport-qld-4215">Maris</a> apartments in Southport, with 75 per cent of residences already sold ahead of launch, the strongest sales result of any new Gold Coast project.&nbsp;

The strong sales momentum highlights renewed buyer confidence in the urban revival of the <a href="https://www.apartments.com.au/developments/southport-qld-4215">Southport</a> CBD.

Maris will rise 20 levels from its Queen Street location and delivering 192 one- and two-bedroom apartments, with the flexibility to combine into larger three-bedroom homes, a response to shifting buyer demand for adaptable urban living.&nbsp;

Designed by Plus Studio, Maris represents one of the most significant residential projects in the Southport pipeline.&nbsp;

The final release of the upper-level apartments, many with sweeping views across the Broadwater and city skyline, is expected to drive further interest when released to market later this year.&nbsp;

MRCB International CEO Ravi Krishnan said the response had exceeded expectations and reinforced confidence in Southport’s long-term investment appeal.&nbsp;

“Maris has resonated with buyers who recognised the value in Southport’s transformation,” said Krishnan.&nbsp;

“The demand we’ve received so far validated our approach to creating considered, lifestyle-driven residences in locations with strong infrastructure and long-term growth prospects.

“Officially launching the project is a significant milestone for us. It’s the culmination of years of planning and local engagement, and we’re proud to be bringing a project of this quality to market at a time when well-located housing is in high demand.&nbsp;

“For MRCB International, it reinforces our commitment to the Gold Coast and our belief in the region’s future as one of Australia’s most liveable urban centres.”&nbsp;

Located on the site of the former Sundale Motel, demolition is now complete, with construction expected to commence in the second half of 2025. Completion is anticipated in 2028.&nbsp;

Maris will deliver a comprehensive resident amenity offering, including a rooftop yoga and dining terrace, a podium-level pool, gym, sauna and a resident lounge.

Positioned directly opposite the Broadwater Parklands light rail station, the development offers walkable access to major retail and dining at Australia Fair, and the proposed Olympic arena at Carey Park, expected to be a catalyst for future infrastructure investment in the lead-up to the 2032 Games.&nbsp;

Recent research from Urbis confirmed Maris was the largest contributor to new apartment sales across the Gold Coast during the March quarter, accounting for 80 of the 209 sales recorded city-wide.&nbsp;

“We’re focused on delivering projects that reflect how people want to live. Connected, well-designed and future-focused,” Krishnan added.&nbsp;

“Southport is undergoing a significant evolution, and Maris is designed to meet the needs of buyers seeking quality homes in vibrant, well-located communities.”&nbsp;

The launch of Maris follows the success of MRCB International’s flagship 26 Vista development in Surfers Paradise, which emerged as one of the fastest-selling apartment projects on the Gold Coast in 2023 and 2024.&nbsp;

[smartcode_project_cta:default project_id=134403]

MRCB launches Southport Maris apartments

Brisbane developer Carbone Developments has lodged plans for its sixth residential project in Windsor, on the city’s northside.

The family-run builder–developer, which is currently delivering Amado Windsor, is proposing one of its largest projects to date, an <a href="https://www.apartments.com.au/new-apartments/42-federation-street-windsor-qld-4030">88-apartment development</a> spanning three adjoining lots on Federation Street.

The 2,023 sqm site sits within the Windsor East precinct of the Lutwyche Road Corridor Neighbourhood Plan, an area earmarked for higher-density residential growth.

<img alt="Carbone windsor podium" data-entity-type="file" data-entity-uuid="5d466d70-52a1-4db4-b005-b7d96266e16e" src="https://s3.ap-southeast-2.amazonaws.com/www.urban.com.au/s3fs-public/inline-images/Carbone%20Windsor%20podium.png?VersionId=xPtW9N2b3zRnfO5TNVx0ApsRGqz59tns" />

Designed by <a href="https://www.apartments.com.au/architects/angelo-patrick-architects">Angelo Patrick Architects</a>, the new project will be a mix of just one and two-bedroom apartments, a mix which struck a chord at Amado which is less than 750m away.

Car parking is contained within podium levels, with access via both Federation and Addison Streets.

The site is currently vacant and surrounded by a mix of older housing stock and newer apartment buildings.

“The precinct is clearly transitioning to higher density residential uses,” the documents submitted to the Brisbane City Council noted. The reports suggested the proposed scale is considered an appropriate response to the intended future character of the area.

The Carbone family, led by brothers Tony and Don Carbone, has been developing new apartments across inner-city&nbsp;<a href="https://www.apartments.com.au/developments/brisbane-qld" target="">Brisbane</a>&nbsp;for the best part of two decades.

First look: Carbone makes next Windsor play

Burgeoning national developer Fortis has spent $37.5 million on one New Farm's most sought-after streets, the highest price ever paid for a development site in the affluent Brisbane suburb.

They've settled on a rare and prized 5,272 sqm block on Bowen Terrace, which runs from the heart of New Farm to the foot of the Story Bridge.&nbsp;It was also the only available residential development site of this scale offered in New Farm for more than a decade.

The site, which is completely cleared and vacant, was sold by Ozcare, who have recently completed a new aged care facility in Newstead.&nbsp;Funds from the sale will be used to develop more aged care facilities for some of Queensland’s most vulnerable senior citizens.&nbsp;

<a href="https://www.apartments.com.au/project-marketer/colliers">Colliers</a> Queensland agents Brendan Hogan and Troy Linnane sold 424 Bowen Terrace,&nbsp;alongside Gallus Partners agent John Shepherd, the cleared and vacant site at

Hogan said the site attracted strong interest from &nbsp;local, national and international developers, drawn by the site’s scale and location in best luxury &nbsp;residential precincts. The EOI campaign was hotly contested with well over 100 enquiries and eight offers received at the close of the process.&nbsp;

“As the only residential development site of this scale offered in New Farm for more than a decade, the &nbsp;property attracted significant interest from premium developers,” Hogan said.&nbsp;

“Fortis presents a compelling vision for a high-quality project that responds to the growing demand &nbsp;from local owner-occupiers seeking larger, design-led apartments. This is a major opportunity to create &nbsp;something truly exceptional in Brisbane’s most prestigious suburb.”&nbsp;

Fortis has lodged development plans with Brisbane City Council for the site, proposing a landmark residential project designed by DKO Architecture. The scheme comprises 74 luxury apartments and four freehold homes.&nbsp;

Read more:&nbsp;<a href="https://www.apartments.com.au/news/qld/fortis-files-bowen-terrace-new-farm-apartment-plans">Fortis files Bowen Terrace, New Farm apartment plans</a>

Strong demand for expansive Bowen Terrace site signals resurgence of Brisbane’s apartment market 

Fortis settles on record $37.5 million New Farm site

In Brighton, where detached homes and long-settled streetscapes remain the norm,&nbsp;<a href="https://www.apartments.com.au/new-townhouses/elema-brighton-155-157-north-road-brighton-vic-3186">ELEMA</a> introduces a different model for high-quality housing.&nbsp;

Developed by <a href="https://www.apartments.com.au/developers/kervale">Kervale</a>, this new collection of 12 townhomes is underpinned by the four classical elements, earth, water, air, and light, not as styling cues, but as structural and spatial drivers across architecture, interiors, and landscape.

Designed by&nbsp;<a href="https://www.apartments.com.au/architects/martinoleah">Martino Leah</a>&nbsp;with interiors by Brahman Perera and landscaping by&nbsp;<a href="https://www.apartments.com.au/landscape-architect/acre">Acre</a>, the project responds to what Kervale identifies as a gap in the local Brighton housing market: mid-sized homes with character, amenity, and a genuine sense of community.&nbsp;

ELEMA’s configuration reflects this intent, with a horseshoe-shaped layout wrapped around a central garden, promoting passive ventilation and privacy without isolating residents.

Each home spans three levels and includes three bedrooms, 2.5 bathrooms, a study, and two car spaces, with internal areas up to 182 sqm and external zones up to 95 sqm.

Two of the twelve townhomes include private plunge pools with heated spa functionality in addition to pre-provisioning for internal passenger lifts. Prices start from $1.7 million, targeting aspirational Bayside owner-occupiers in their mid-30s to 60s seeking entry into Brighton’s tightly held upper market.

[smartcode_project:default project_id=145418 project_image_fid=300804]

‘Earth’ is expressed in the project’s grounded material palette and connection to site. Natural stone, granites and timber finishes in earthy hues are used consistently throughout, anchoring the homes in their context while supporting thermal mass.&nbsp;

Landscaped courtyards and native planting schemes featuring predominantly Australian Native species, developed by Acre, extend the concept beyond built form, using layered, low-maintenance vegetation to root the development in <a href="https://www.apartments.com.au/developments/brighton-vic-3186">Brighton</a>’s coastal ecology.

The site layout follows a horseshoe configuration, creating a central communal courtyard that provides both visual outlook and passive environmental benefits. This arrangement improves daylight access, facilitates cross-ventilation, and introduces a shared green space without compromising individual privacy.

[smartcode_project:default project_id=145418 project_image_fid=300809]

‘Water’ is introduced subtly but purposefully. Select townhomes include private plunge pools, integrated into rear terraces without visual dominance. These pools are designed for quiet retreat, and their placement reinforces the project’s broader focus on functional outdoor spaces that support private use rather than spectacle.

‘Air’ is enabled through architectural planning. The horseshoe site layout creates generous setbacks and enables cross-ventilation through each residence.&nbsp;

[smartcode_project:default project_id=145418 project_image_fid=300803]

‘Light’ is a defining component of both the architecture and interiors. Large-format glazing opens living areas to courtyards and terraces, while the façade screening filters daylight to reduce glare and soften internal environments.&nbsp;

Internally, Perera’s palette of muted tones and tactile finishes is designed to respond to natural light conditions, shifting in tone and texture throughout the day.

[smartcode_project:default project_id=145418 project_image_fid=300810]

ELEMA reflects a broader shift in how high-value suburbs are adapting to changing housing needs - away from uniformity, toward diversity in form, scale and function.

Rather than replicate detached housing models, ELEMA proposes an alternative built around balance, between public and private, built form and natural, permanence and flexibility. In doing so, it reframes the townhome as a highly resolved housing type capable of responding to both environmental and lifestyle needs.

ELEMA also targets an average 7-star NatHERS energy rating, supported by solar panels, drought-tolerant landscaping and high-spec energy-efficient appliances.

Three-bedroom townhomes at ELEMA Brighton are priced from $1,700,000.

[smartcode_project_cta:default project_id=145418]

Urban Editorial

Inside ELEMA Brighton: Designing with the elements

Currency

<html><body>
EXPERT OBSERVER
There’s no trading strategy that will deliver better returns than chance.
In 2013 I wrote a <a href="https://theconversation.com/gambling-on-the-dollar-time-to-reign-in-forex-trading-21150" target="_blank">piece on The Conversation</a> arguing that foreign exchange trading should be much more tightly regulated.
In particular, I said that retail (mum and dad) investors should only be allowed to trade foreign currencies in limited circumstances. Since then there has been little change. It is still shockingly easy for a retail investor with a very limited understanding of foreign currency to trade foreign exchange, as was demonstrated on ABC 7.30 on <a href="https://www.propertyobserver.com.au/https://www.abc.net.au/7.30/the-risky-world-of-online-foreign-exchange/10922394" target="_blank">Wednesday</a> and <a href="https://www.propertyobserver.com.au/https://www.abc.net.au/7.30/the-opaque-world-of-foreign-exchange-trading/10927348" target="_blank">Thursday</a> nights.
There is a basic difference between foreign exchange trading and other forms of investment such as share trading. Over time, share markets tend to rise, so that if an investor buys a diversified basket of shares, or even an individual share, they should expect a positive return over time. Of course markets go up and down, and individual share trades can go wrong, but in the long run the market tends to rise.
<h2>Share trading it isn’t</h2>
Foreign currency markets are fundamentally different, in that there is no reason to expect exchange rates such as the Australian-US dollar rate to rise or fall over any short- or medium-term trading horizon.
For 30 or more years, academics have tried to build models to predict exchange rates. None of them work. If even the most sophisticated academic or trader built a model to predict whether the AUD/USD would go up or down tomorrow, they would get it wrong 50% of the time – exactly the same as a coin toss. This means trading foreign exchange on the basis of whether major currencies will go up or down is exactly the same as playing <a href="https://en.wikipedia.org/wiki/Two-up" target="_blank">two-up</a>!
<h2>Losses can exceed what you put in</h2>
The second reason that retail investors should be wary of foreign exchange trading is that many promoted products are highly leveraged - funded by borrowing. The Australian Securities and Investments Commission has <a href="https://www.moneysmart.gov.au/investing/complex-investments/foreign-exchange-trading" target="_blank">clear warnings about foreign exchange trading</a> on its Moneysmart webpage, including a case study of a typical trader who invests A$500 to borrow to buy A$100,000 at an exchange rate of 91 US cents.
With this contract, a fall in the USD/AUD exchange rate to 88.5 US cents sees this trader lose A$2,825, meaning they have to pay another A$2,325 in addition to the original A$500 to close out the contract.
<hr>
<a href="https://images.theconversation.com/files/265003/original/file-20190321-93057-1krimjl.JPG?ixlib=rb-1.1.0&amp;q=45&amp;auto=format&amp;w=1000&amp;fit=clip"><img src="https://images.theconversation.com/files/265003/original/file-20190321-93057-1krimjl.JPG?ixlib=rb-1.1.0&amp;q=45&amp;auto=format&amp;w=754&amp;fit=clip" alt=""></a> How to lose a lot from a little. <a class="source" href="https://www.moneysmart.gov.au/investing/complex-investments/foreign-exchange-trading" target="_blank">ASIC MoneySmart</a>
<hr>
If foreign exchange trading is so risky, and in my view no different to playing two-up or roulette, why do we allow retail investors to leverage into these products?
The problem, as I see it, is that regulators can take one of two approaches to investors. The traditional view is that if investors have enough information they will make informed choices in their own best interests. Economists describe this as behaving rationally. The ASIC approach is very much based on this view: provide good information and let investors make informed choices.
<h2>Information isn’t enough</h2>
There is a second view that is gradually replacing this view of individuals as rational. The “behavioural economics” approach examines the psychology and actual approaches of individuals in different circumstances, to explore departures from rationality. Unsurprisingly, in many arenas people are irrational, creatures of habit, ill-informed, and so on.
An implication is that sometimes people ought to be protected from their own poor decisions, even though that might limit choice. I would argue strongly that there is no reason for retail investors to trade foreign exchange, and certainly no reason to borrow to do it. Measures to limit such trading, except in circumstances where an investor can demonstrate their expertise, ought to be encouraged.
<h2>We’re a magnet for promoters</h2>
This is very far from the case in Australia currently. In fact Australia is seen as an attractive location for firms offering retail foreign exchange trading. Websites offer “training and tips” and then allow trading inside 24 hours.
I have spent 30 years studying foreign exchange markets and would still say that I’m not sophisticated enough to trade them. Maybe I’m dumb, but I’m not crazy enough to trade foreign exchange.
<a href="https://theconversation.com/profiles/mark-crosby-444" target="_blank">Mark Crosby</a>, Professor, <a href="http://theconversation.com/institutions/monash-university-1065" target="_blank">Monash University</a>
This article is republished from <a href="http://theconversation.com" target="_blank">The Conversation</a> under a Creative Commons license. Read the <a href="https://theconversation.com/no-better-than-roulette-how-foreign-exchange-trading-rips-off-mum-and-dad-investors-113743" target="_blank">original article</a>.
</body></html>

j.ballantyne1990-6AQqhLzZaK

No better than roulette. How foreign exchange trading rips off mum and dad investors

<html><body>
GUEST OBSERVER
Some initial coin offerings seem like scams (and some are), but behavioural research shows our emotions are part of why people buy in to cryptocurrencies for fruits and vegetables or crypto trading even if cool-headed rationality screams at us not to.
An initial coin offering is just like an initial public offering. But, instead of shares, what’s being sold are cryptocurrency “coins” or “tokens”. These are similar to virtual currencies found in computer games, enabling you to buy goods or services within an ecosystem.
Around half of the initial coin offerings launched last year have already disappeared or failed. This has potentially cost investors hundreds of millions of dollars.
The boom in initial coin offerings is a textbook example of how our emotions drive us to be overly optimistic and to become fixated on the spectacular gains made by others. Companies and designers can also appeal to our emotions and our conceptions of ourselves by appearing to adopt moral positions.
This mix of emotions lets “irrational exuberance” over getting rich quick (while doing the world a favour) overwhelm our reason and willpower.
Early investors in initial coin offerings made an absolute killing, which led to a lot of media coverage of newly minted “crypto-billionaires”.
This is a recipe for creating what’s called “optimism bias” because people become fixated on the spectacular gains made by others, playing into a lust for wealth.
Comparing our meagre incomes to these huge profits also means, deep down, we become terribly afraid of losing our chance at riches, stimulating feelings of stress and what’s known as “loss aversion”.
<img src="https://images.theconversation.com/files/208214/original/file-20180228-36671-19yn96t.jpg?ixlib=rb-1.1.0&amp;q=45&amp;auto=format&amp;w=754&amp;fit=clip" alt="">
A bananacoin is pegged to the export price of one kilogram of bananas.
But even more striking in the boom of initial coin offerings is how many appear to be about some moral initiative, such as supporting sustainable energy, artists, veganism or organic bananas.
In other words, many initial coin offerings tap into a set of emotional impulses associated with morality.
Research in social psychology shows that morals are built on powerful emotions, not reasoning. Signals from our environment go through emotional centres of the brain not only before the reasoning centres, but even before our sensory centres – we “feel” even before we “see”.
Reasoning serves merely to justify emotional reactions. People will justify what they already want to do, or have done, after the fact.
We also know from other research that while reason does give us willpower to resist emotional temptation, it has only a finite capacity to do so and can be overwhelmed.
The moral aspect of initial coin offerings also taps into our conceptions of our own identities. My research shows that if I can find a way that my cryptocurrency (say a cryptocurrency for veganism) would allow you to live out your moral identity (being a vegan) then it’s much easier for me to get the idea into your mind that you should buy it.
Once such ideas are implanted into the mind, they are difficult to restrain.
When we lust for riches, fear being left behind and identify strongly with some moral cause all at once, reason and willpower don’t really stand a chance.
But simply regulating initial coin offerings is difficult. One of the first things you learn in economics is the “law of unintended consequences” – that regulation seldom does only what it was intended to do.
Regulations aimed at protecting individuals from themselves could restrict new technologies and discourage a necessary process – discovering what’s a stupid idea and what is a spectacularly good idea. The line between them is very fine indeed and almost never obvious.
<img src="https://counter.theconversation.com/content/92508/count.gif?distributor=republish-lightbox-basic" alt="The Conversation" width="1" height="1">Among all the crackpots and charlatans we might just discover a technology to educate girls in Africa, fund a breakthrough in clean energy technology, or help to stamp out human rights abuses across the world.
Brendan Markey-Towler, The University of Queensland.
This article was originally published on <a href="http://theconversation.com" target="_blank">The Conversation</a>. Read the <a href="https://theconversation.com/why-we-put-money-into-bizarre-cryptocurrencies-like-ponzicoin-and-cryptokitties-92508" target="_blank">original article</a>.
</body></html>

Why we put money into bizarre cryptocurrencies like ponzicoin and cryptokitties

<html><body>
GUEST OBSERVER
The current international tax regime was developed in the last century when the internet was not yet invented.
At that time, a foreign company would typically require a substantial physical presence in Australia before it could be in a position to earn significant amount of income from Australian customers. This is what’s known in the tax world as permanent establishment.
The concept of permanent establishment is embedded in most domestic tax laws as well as virtually all the 3,000 plus tax treaties in the world. It dictates that in general, business profits of a foreign company will be subject to tax in Australia only if the company has a permanent establishment in Australia. In other words, the ATO cannot tax a foreign company’s profits if it has no permanent establishment in Australia.
The recent hearings of the Senate inquiry into corporate tax avoidance made it clear the tax structures of Uber, Airbnb, like their older peers Google and Microsoft, are designed to ensure income from Australian customers is earned by a foreign company that does not have a permanent establishment here. The permanent establishment concept is not effective for today’s digital economy.
<h2>Uber’s business and tax structure</h2>
Take Uber, which though established in the US, has a wholly-owned subsidiary in the Netherlands, which in turn has a wholly-owned subsidiary in Australia.
The most important asset of Uber is its digital platform that supports the app linking individual drivers and their customers. It’s unlikely this app was developed in the Netherlands. Despite this, Uber-Netherlands has the right to book income generated from customers in Australia.
For example, if a customer pays $100 for a ride in Sydney booked through the Uber app, the money is in fact paid to Uber-Netherlands. Out of the $100, Uber pays the driver about $75. The gross profit of $25 is booked in the Netherlands. This is so even though the transaction happens largely in Australia, including the driver, the customer and the ride.
Uber-Australia receives a service fee from Uber-Netherlands for its marketing and support services performed in Australia. The fee is determined based on the operating costs of Uber-Australia, plus a mark-up of 8.5%. The mark-up is effectively the taxable profit of Uber in Australia under its tax structure.
<h2>Airbnb’s business and tax structure</h2>
Airbnb, another young business founded in the US, has a structure very similar to that of Uber. Airbnb’s parent company in the US has a wholly-owned subsidiary in Ireland, which in turn has a wholly owned subsidiary in Australia.
Airbnb charges fees to both hosts and guests for accommodation booking through its digital platform. Instead of Airbnb-Australia, Airbnb-Ireland books the fee income generated from accommodation bookings in Australia. This is so even if the host, the guest and the accommodation are all in Australia. For example, if a Sydneysider uses the Airbnb app to book accommodation in Melbourne, the payment is in fact paid to Airbnb-Ireland. The host of the accommodation is then paid by Airbnb-Ireland which charges a fee of 3%.
Airbnb-Australia is responsible for the marketing activities in Australia. It receives a service fee from Airbnb-Ireland for those activities, and the fee is again computed based on its operating costs plus a mark-up.
<h2>Déjà vu – Google and Microsoft</h2>
Comparing the tax structures of Uber and Airbnb with that of Google and Microsoft reveals striking similarities. It suggests that the appetite for tax planning is comparable between established and relatively “young” technology companies.
The common pattern: a parent company in the US establishes wholly owned subsidiaries in market jurisdictions (such as Australia) as well as in low-tax countries.
While the commercial reality is that all companies in a group are effectively one single enterprise, the tax law in general treats each company as a separate taxpayer.
On one hand, the Australian subsidiary typically is responsible for marketing and support services that have to be physically done in Australia, and earns a service fee on a cost plus basis. The amount of profits subject to tax in Australia is usually very small compared to the income generated from Australian customers.
On the other hand, intellectual properties – which are often the most important and valuable assets of technology companies – are located in low-tax jurisdictions such as Ireland, the Netherlands and Singapore. This structure allows those low-tax subsidiaries to book the income generated from customers in Australia, and effectively shields the income from the Australian tax net.
<h2>Policy responses</h2>
Action item 1 of the OECD’s base erosion and profit shifting (“BEPS”) project is “tax challenges of digital economy”.
The original intention of the OECD was to explore how the 20th century international tax regime should be reformed in response to the digital economy in the 21st century. It quickly realised it was extremely difficult, if not impossible, to achieve international consensus on the intended reform. The often conflicting and vested interests among countries present a formidable obstacle to international consensus on meaningful reform of the international tax regime.
Instead of relying on the BEPS project to resolve the issue, Australia has followed the lead of the UK and is in the process of introducing the Multinational Anti-Avoidance Law – commonly known as the Google tax– to address the issue. As the new law incorporates concepts that are new and untested, it is not clear whether it will be effective.
In any case, it’s important to remember that multinational corporations are very agile. They may replace their “avoided permanent establishment” structures to circumvent any Google tax or to incorporate new tax avoidance tools.
 
Antony Ting is associate professor, University of Sydney and author for The Conversation. He can be contacted <a href="https://theconversation.com/profiles/antony-ting-117958" target="_blank">here</a>.
</body></html>

Currency

Editor's Picks

Have something to contribute?

The latest real estate & off the plan properties & news, delivered to your inbox.

Developments

New apartments

New townhouses

News

The latest real estate & off the plan properties & news, delivered to your inbox.

Currency

Editor's Picks

Receive the latest news stories to your inbox

Have something to contribute?

The latest real estate & off the plan properties & news, delivered to your inbox.

Developments

New apartments

New townhouses

News

The latest real estate & off the plan properties & news, delivered to your inbox.