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New draft ruling on the taxation of earn out arrangements.

Publication date: 02 Nov 07 | Source: WEEKLY TAX BULLETIN

Issue: No 46 2007

Pages: pp.1859-

On 17 October 2007, the ATO released Draft Taxation Ruling TR 2007/D10 on the tax treatment of 'earn out arrangements' where, on the sale of a business or asset, some part of the agreed price in contingent on future economic performance. The Draft Ruling alters quite significantly for a buyer some of the analysis of earn out arrangements expressed in the ATO's earlier Ruling on the subject.

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Author profiles

Prof Graeme Cooper FTI
Photo of author, Graeme COOPER Graeme is Professor of Taxation Law at The University of Sydney and a consultant to Greenwoods & Herbert Smith Freehills. He is a former Chair of the New South Wales State Council of The Tax Institute and former member of the National Council. He has worked as a consultant to the ATO, Treasury, Board of Taxation, United Nations, OECD, World Bank, the International Monetary Fund and several foreign governments. He was admitted to legal practice in New South Wales and Victoria, and practised commercial law and tax in Sydney before entering teaching. He has taught in law schools in Australia, Europe and the United States, and holds degrees from the University of Sydney, University of Illinois and Columbia University, New York. - Current at 26 June 2019
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