Tony Frost FTIA (Greenwoods and Freehills) is representing the Taxation Institute at the NTLG Finance and Investment Subcommittee TOFA Working Group meeting today, Friday 6 March 2009. The meeting will consider the 28 principally interpretative and administrative issues raised in a teleconference on Monday 2 March 2009 of the external members of the Working Group. Some of the key issues raised include:
- deductibility of dividends and timing of deduction (s 230-15);
- PAYG implications (s 230-15(7));
- gains that can be treated as non assessable non exempt (NANE) income (s 230-30(2));
- definition of financial arrangement: equity interests that also satisfy s 230-45;
- whether deferred purchase agreements (DPAs) are financial arrangements (s 230-45);
- notional principal arrangements (e.g. interest rate swaps and other types of swaps) (s 230-120); and
- Effective Interest method and its operation (ss 230-115(4), 230-140(3)(f)).
A report on key issues arising from this meeting and the preceding meeting of the NTLG Finance and Investment Subcommittee, if any, will be provided next week.