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Taxation of financial arrangements implications for SMEs paper


The TOFA rules will have significant implications for many SMEs. Issues discussed in this paper include:

  • the scope of the legislation - how wide is the definition of “financial arrangement” and what taxpayers will be impacted?
  • a practical application of the proposed rules
  • update on issues such as:
    • FX denominated bank accounts
    • short term foreign exchange gains/losses
    • at call loans
  • the continuing interaction of pre TOFA rules, existing TOFA rules and the proposed rules.
This was also presented by Fiona Cahill at the 'TOFA - Implications for SMEs' seminar held in Perth on 22 May 2007.

Author profile:

Neil Ward FTI
Neil is a Partner at Deloitte. Neil has more than 25 years experience advising on tax. During this period he has advised on most aspects of corporate taxation both from an Australian and International perspective. Neil has had significant experience with tax consulting to the banking and finance sector. Neil is recognised as one of the leading tax advisers on financial arrangements, foreign exchange, thin capitalisation and infrastructure transactions and has been actively involved in the tax reform of financial arrangements. Current at 01 June 2009 Click here to expand/collapse more articles by Neil WARD.

This was presented at 22nd National Convention: Tackling Tax.

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