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TOFA–The international dimension paper

Publication date: 13 Feb 09

Source: NATIONAL DIVISION, THE TAX INSTITUTE

Abstract:

This paper examines:

• the application of TOFA to cross border financial transactions
• how TOFA affects foreign banks, internal transactions of banks and OBUs
• interaction with the rules on forex gains/losses, withholding tax and CFC/FIF regimes
• change of residence by companies and individuals.

Author profile:

Anthony Frost CTA
Tony is the Managing Director of Greenwoods & Freehills. With more than 25 years experience in tax, Tony has a focus on financial services and financial transactions. Tony has advised clients on a wide range of tax matters, including innovative financial products, mergers and acquisitions, crossborder dealings, transfer pricing, tax audits and negotiations with the Australian Taxation Office. For better or worse, Tony has been involved in the taxation of the financial arrangements reform project since its inception in 1991 and spoke on the same topic at the 11th National Convention in 1993.
Current at 16 November 2012
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Purchase individual materials from this event:

Hedging workshop
Author(s):  Julian HUMPHREY

TOFA and hedging
Author(s):  Mathew UMINA

Tax issues in a bear market: Assets side
Author(s):  Allan BLAIKIE

Tax issues in a bear market: Liabilities side presentation
Author(s):  Patrick BROUGHAN

Profit attribution to permanent establishments and transfer pricing following the Roche case
Author(s):  Nick HOUSEMAN

Financial services tax update
Author(s):  Antoinette ELIAS

Thin capitalisation including the impact of falling asset values
Author(s):  Paul BALKUS,  Daryl CHOO

Developments in the administration of promoter penalties
Author(s):  Bruce COLLINS

The capital revenue debate and the managed funds review
Author(s):  Andrew MILLS

Managing TOFA, implementation and ongoing–Tax Office perspective
Author(s):  Ross BROOKES

Managing TOFA, implementation and ongoing–The TOFA countdown has begun
Author(s):  Neil WARD

Annual compliance arrangements
Author(s):  Stephen GREEN

Superannuation update
Author(s):  Shayne CARTER

TOFA for the clients of financial institutions
Author(s):  David LINKE

TOFA–The international dimension
Author(s):  Tony FROST

Walking the wire-The Australian economy in 2009
Author(s):  Michael BLYTHE