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TOFA- A practical application of the proposed rules


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:

Neil Ward FTI
Neil is a Partner at Deloitte. Neil has more than 25 years experience advising on tax. During this period he has advised on most aspects of corporate taxation both from an Australian and International perspective. Neil has had significant experience with tax consulting to the banking and finance sector. Neil is recognised as one of the leading tax advisers on financial arrangements, foreign exchange, thin capitalisation and infrastructure transactions and has been actively involved in the tax reform of financial arrangements. Current at 01 June 2009 Click here to expand/collapse more articles by Neil WARD.
Author Photo - Alexis Kokkinos ATI
Alexis Kokkinos ATI
Alexis is a Partner of the Tax Consulting group of Pitcher Partners and has over 19 years experience in advising corporate clients. Alexis was a member of the Board of Taxation review on the tax consolidation measures and was also a member of the Treasury review of MEC groups. Current at 09 July 2015 Click here to expand/collapse more articles by Alexis KOKKINOS.
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