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Practical TOFA considerations for corporates paper


The TOFA legislation received Royal Assent six months ago and early electing taxpayers may in
some cases be already subject to the new rules. There is still time before the first TOFA elections need to be made.

This paper covers a number of practical issues that have become relevant in determining the potential impact of TOFA and is intended to help with your decisions on the various elections available. It includes a practical analysis supported by case studies covering:

  • a suggested approach to determining the preferable TOFA position
  • is tax hedging as beneficial as it appears and how is it achieved?
  • when would you consider the accounting based elections?
  • TOFA issues still under consultation.

Author profile

Neil Ward
Neil Ward FTIA leads the Deloitte Australian Financial Services Tax Group. He has more than 30 years experience in advising in tax. Prior to joining Deloitte in March 2000, Neil spent 12 years with the ANZ Banking Group in Australia and the United Kingdom. Neil is recognised as one of the leading tax advisers on financial arrangements, foreign exchange, thin capitalisation, capital management, withholding tax and infrastructure transactions. - Current at 06 May 2009
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This was presented at 48th Victorian State Convention .

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Individual sessions

Managing trust losses

Author(s):  Meagan O'CONNOR,  Rob JEREMIAH

Materials from this session:

Division 7A the 'sleeping giant'

Author(s):  David STAVROPOULOS

Materials from this session:

Bamford v Federal Commissioner of Taxation

Author(s):  Terry MURPHY

Materials from this session:

Trusts and distribution resolutions in the light of Bamford

Author(s):  Nabil (Bill) F. OROW

Materials from this session:

Inbound investment emerging issues

Author(s):  Vik KHANNA

Materials from this session:

Further details about this event:


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