17 Nov 088 Arrangements to shift foreign business losses into Australian branches or resident entities - TA 2008/18On 13 November 2008, the ATO issued Taxpayer's Alert TA 2008/18 entitled "Arrangements to shift foreign business losses into Australian branches or resident entities". The Alert describes arrangements within multi-national companies operating through branches, or operating through transactions with foreign associates, which seek to shift deductions for losses from foreign operations into their Australian businesses.
In a media release issued the same day, the Commissioner, Michael D’Ascenzo, said: “We have seen attempts to aggressively transfer existing or unrealised losses from the foreign operations of another business into Australia, possibly as a result of the current global economic environment.”
The ATO is currently reviewing these arrangements.
For a copy of TA 2008/18, go here.
For a copy of the ATO media release, No 2008/55, 13 November 2008, go here.