Beware 47A!
Publication date: 01 Apr 07
Source: "THE TAX SPECIALIST" JOURNAL ARTICLE
Abstract:
Section 47A is an anti-avoidance provision that deems certain benefits provided by Controlled Foreign Companies to other entities to be dividends. The ATO has recently released Draft Taxation Determination TD 2007/D1 which outlines the application of section 47A to situations where a CFC provides these covered benefits to another associated CFC. This article analyses the ATO’s reasoning and conclusions in the Draft Determination.
Author profile:
Dr Philip BenderPhilip Barrister at Law, Victorian Bar has many years experience in advising on international tax, including structuring of managed funds and other inbound and outbound investments. Philip advises and appears regularly for taxpayers and the Commissioner in both the AAT and Federal Court, including on international tax matters. He also appears in commercial and trust matters in State Courts. Philip is also a contributing author to 2 books (Taxation of Financial Arrangements and Business Tax Reform in Prospect and Retrospect) and has published numerous articles on international tax issues.
Current at 26 August 2011
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