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The pending taxation of financial arrangements regime - practical analysis paper


The policy behind Treasury’s long-awaited proposals relating to the taxation of financial arrangements (TOFA) remains unsettled. However, this paper considers possible practical implications of TOFA for those outside of the finance sector, in relation to common-place transactions including:

  • the acquisition or construction of major assets
  • the disposal of significant assets on deferred settlement terms
  • contracts such as lease and service agreements.

Author profiles:

Kenneth Spence CTA-Life
Ken is a Special Counsel in the Melbourne office of Greenwoods & Herbert Smith Freehills. He has been closely involved for many years in advising Australian and foreign-owned listed companies on M&A transactions and has been extensively involved with both clients and tax professional bodies in relation to all aspects of the tax consolidation regime. Ken is a past President of The Tax Institute. Current at 23 August 2016 Click here to expand/collapse more articles by Ken SPENCE.

Click here to expand/collapse more articles by Simon HAINES.

Enzo Coia CTA
Formerly a senior associate with Shaddick & Spence, Enzo is a Senior Associate with Greenwoods & Freehills. Current at 05 May 2009 Click here to expand/collapse more articles by Enzo COIA.

This was presented at 45th Victorian State Convention: Finding buried treasure.

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Individual sessions

CGT Rollovers: restructuring for the top end

Author(s):  Richard CZERWIK,  Stephen CARPENTER

Materials from this session:

International tax - there's treasure buried all over the world

Author(s):  Liam COLLINS

Materials from this session:

Consolidation...unfinished business

Author(s):  Michelle DE NIESE

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The 'ins' and 'outs' of testamentary trusts

Author(s):  Bruce COOK

Materials from this session:

Exploring new waters - emerging trust issues

Author(s):  Graeme HALPERIN

Materials from this session:

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