Under the arrangement, the marketer of the scheme sets up an employee entitlement fund in Australia or another country on behalf of an employer, promising they will regain access to any contributions made to the fund. The employer then makes contributions to the fund alleging that the amounts will be set aside to meet future employee entitlements. They then claim a deduction from the ATO for the contributions. However, the scheme marketer then returns the funds to the employer via other parties.
The ATO is examining these arrangements.
For a copy of the ATO media release, No Nat 2007/14, 3 May 2007, go here
For a copy of TA 2007/2, go here