17 Dec 099 Treaty shopping and Part IVA - TD 2009/D17
This draft Taxation Determination was released on 16 December 2009 for public comment by 29 January 2010. Its full title is "Income tax: treaty shopping - can Part IVA of ITAA 1936 apply to arrangements designed to alter the intended effect of Australia's International Tax Agreements network?" The answer given is Yes, subject to certain conditions being satisfied. The issue of this draft Taxation Determination follows the much publicised TPG/Myer transaction.
For a copy of TD 2009/D17, go here