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Taxation of financial arrangements paper


This paper provides a progress report on the TOFA rules in Div 230 of the Tax Act which have substantially reshaped the way that many taxpayers have to recognise financial transactions for tax purposes.

Topics covered include:

  • TOFA overview
  • where the law is at now and current TOFA issues
  • ATO compliance activities – focus areas of ATO review
  • risk management
  • was TOFA a good idea and what can be done to improve it?

Author profiles

Anthony Frost CTA
Photo of author, Tony FROST Tony is the Managing Director of Greenwoods & Freehills. With more than 25 years experience in tax, Tony has a focus on financial services and financial transactions. Tony has advised clients on a wide range of tax matters, including innovative financial products, mergers and acquisitions, cross-border dealings, transfer pricing, tax audits and negotiations with the Australian Taxation Office. Tony has also advised clients on various OBU matters over many years, and is part of the consultation group set up by Treasury to discuss changes to the OBU rules announced in the previous government’s 2013-14 Budget. - Current at 18 October 2013
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Andrew Hirst CTA
Andrew, CTA, is a Director at Greenwoods & Herbert Smith Freehills Pty Limited. Andrew advises on a wide range of corporate and banking-related tax issues with a particular focus on financial and international transactions. Andrew has been extensively involved in the development of the TOFA provisions and represented The Tax Institute before the House of Representatives Economic Committee in relation to recent changes in this area. - Current at 17 March 2016
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This was presented at The 28th National Convention .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Taxation of financial arrangements

Author(s):  Tony FROST,  Andrew Hirst

Materials from this session:

Australian Taxation Office investigations - Recent issues

Author(s):  Michael CLOUGH,  Andrew CURRIE

Materials from this session:

Powers of Attorney

Author(s):  Susan Fielding

Materials from this session:

Tax issues on intergenerational change

Author(s):  Peter BOBBIN

Materials from this session:

Equity, simplicity, certainty and individualised justice – in the one sentence?

Author(s):  Michelle GORDON

Materials from this session:

Part IVA reform

Author(s):  AH (Tony) SLATER

Materials from this session:

Further details about this event:


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