Submissions

The Tax Institute is the most respected and influential contributor to the development of tax policy and administration in Australia. As part of this contribution, we prepare top level submissions on tax policy, administration and technical matters at both Federal and State levels. Non-confidential submissions prepared from 1996 onwards and covering legislation, ATO and Treasury consultative documents and papers, as well as rulings, determinations and a range of other ATO opinion and guideline documents, are available here.

  • Dividend Washing

    15 Apr 2014

    The Tax Institute welcomes the opportunity to make a submission to the Treasury inrelation to the Tax and Superannuation Laws Amendment (2014 Measures No. 2) Bill2014: Preventing distribution washing (Exposure Draft).

  • Review of the Thin Capitalisation Arm’s Length Debt Test

    25 Mar 2014

    The Tax Institute is pleased to have the opportunity to make a submission to the Board of Taxation (Board ) in relation to its Discussion Paper dated December 2013 on the arm’s length debt test (ALDT ) as it applies to the thin capitalisation rules (Discussion Paper ).

  • Deregulation in the tax system

    19 Mar 2014

    The Tax Institute supports the Government’s deregulation initiative and the publishing of a regulation impact statement in respect of each new tax measure. Careful consideration should be given to how the success of this initiative ought to be measured. It is our view that this initiative should be clearly distinguished from the repeal of redundant provisions, with the focus being on genuine time and cost savings for users of the tax system.

  • 2014-15 Federal Budget Submission

    10 Mar 2014

    The Tax Institute is pleased to respond to the invitation from the Treasurer, The Hon Joe Hockey MP, to submit our ideas and priorities for the 2014-15 Budget.

    We trust that this submission will assist inproviding an insight into the opportunities to improve tax policy outcomes for all Australians.

    The Tax Institute is Australia’s leading professional association in tax, with more than 14,000 taxmembers. Further details about The Tax Institute are included at Appendix A.

  • Investment Manager Regime – Element 3 Exposure Draft Legislation

    18 Feb 2014

    The Tax Institute welcomes the opportunity to lodge a submission in relation to the thirdround of exposure draft legislation in the form of the Tax Laws Amendment (2013Miscellaneous Measures No. 1) Bill 2013 (the “Bill”). The Bill deals with the proposedintroduction of the Australian investment manager regime (“IMR”).

  • Employee Share Schemes and Start-ups

    12 Feb 2014

    Our submission addresses our main concerns in relation to the issue. In particular:

    • There are a number of difficulties with the existing employee share scheme rules, and we would welcome this opportunity to fix the rules for all affected employers and employees, not just start-ups.
    • We are concerned about the high costs of compliance with employee share scheme rules for all companies, but particularly the costs of valuations for unlisted companies. We would suggest that unlisted companies be able to take a balance sheet approach to base the share value on the net assets of the company disclosed in the financial statements.
    • We would support a method which allows the payment of tax to be deferred until a year in which the employee is able to realise the value of their shares/options.

  • Child care and tax deductibility

    06 Feb 2014

    The Tax Institute is pleased to present our submission to the Productivity Commission’s inquiry into future options for child care and early childhood learning, with a focus on developing a system that supports workforce participation and addresses children's learning and development needs.

  • Draft Practice Direction for the Expedited Review of Certain Decisions

    31 Jan 2014

    This submission addresses our main concerns in relation to the draft practice direction. In particular:

    • The draft practice direction should not apply to most tax decisions, by ”tax decision” we mean a decision subject to appeal under Part IVC of the Taxation Administration Act 1953 (TAA). If the draft practice direction is to apply to all tax decisions, amendments to paragraphs 1.3, 2.1 and 2.5 are required to clarify this;
    • There should be flexibility as to the timing of an application for expedited review;
    • The draft practice direction should clarify whether both the applicant and the respondent can apply for expedited review; and
    • The prejudice to the responding party should be a matter the Tribunal considers in determining an application for expedited review.

  • Restoring Integrity in the Australian Tax System

    14 Nov 2013

    The Tax Institute takes this opportunity to make a submission in relation to the 64 previously announced measures which are subject to further consultation to determine whether the Government should proceed with these measures.

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