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Part IVA Assessments: Can the Commissioner have his Cake and Eat it Too?

Published on 01 Apr 03 by "THE TAX SPECIALIST" JOURNAL ARTICLE

This article looks at the consequences that flow from the Commissioner's current administration practice of seeking to rely on more than one amended assessment when attacking the deductibility of payments made pursuant to so called Part IVA arrangements. It is concluded that a second amended assessment based on Part IVA can only be a valid assessment if the Commissioner concedes that the payment is otherwise deductible.

Author profile:

Leigh Baring CTA
Leigh has been a Partner in the Maddocks tax and revenue practice group for over 15 years. He has extensive experience in advising corporates, high net worth individuals, accountants and financial advisers on all areas of taxation law. Leigh regularly provides advice on structuring of businesses and transactions, mergers and acquisitions, corporate reorganisations and distributions, sale of businesses, demergers, capital raisings, joint ventures and property developments, international tax (both inbound and outbound), succession planning and liquidations. His advice covers both direct and indirect tax considerations. Current at 03 July 2014 Click here to expand/collapse more articles by Leigh BARING.
 
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