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TOFA- A practical application of the proposed rules

Published on 01 Aug 06 by "THE TAX SPECIALIST" JOURNAL ARTICLE

TOFA will fundamentally change the tax profile of financial arrangements. Irrespective of what choices taxpayers make they need to understand the potential ramifications of the TOFA reform. This article will explore the basis of the current proposals and provide an analysis of examples to give an insight into its potential application.

Author profiles:

Author Photo - Alexis KOKKINOS
Alexis KOKKINOS

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Neil WARD
Neil Ward FTIA leads the Deloitte Australian Financial Services Tax Group. He has more than 30 years experience in advising in tax. Prior to joining Deloitte in March 2000, Neil spent 12 years with the ANZ Banking Group in Australia and the United Kingdom. Neil is recognised as one of the leading tax advisers on financial arrangements, foreign exchange, thin capitalisation, capital management, withholding tax and infrastructure transactions.
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