Published on 08 Oct 05
by VICTORIAN DIVISION, THE TAX INSTITUTE
No recent issue has aroused the interest of tax practitioners as much as the ATO's new approach to Service Trusts. This paper critically considers the ATO's recently published views and consider whether in fact anything has changed!
- Phillips case - why it prevailed
- can the Commissioner now say 'how much a taxpayer ought to spend in obtaining his income'?
- is the Ronpibon/Cecils Bros principle dead?
- 'aggressive' service trust arrangements In the light of Phillips case and Part IVA
- are service trusts still effective asset protection strategies?
- does the ATO booklet on service trusts require transfer pricing principles to be applied when determining deductibility?
This was also presented on 15 October 2005 at the Tasmanian State Convention in St Helens.
QC CTA - Life
John de Wijn, graduated from Monash University in 1974 with a Bachelor of Jurisprudence and a Bachelor of Law (Hons). In 1978, he obtained a Master of Philosophy from the University of Southampton having completed a thesis on international tax. After practising as a solicitor for about nine years, John came to the Vic Bar in 1984 and took silk in 1997. He has practised predominantly in revenue law.
- Current at
01 July 2015