Published on 09 Oct 09
by VICTORIAN DIVISION, THE TAX INSTITUTE
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.
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
Current at 11 March 2009 Current at 06 April 2009
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