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23 Jul 10 National Tax Liaison Group (NTLG) Finance & Investment sub-committee

Tamera Cockerill ATIA, Tony Frost FTIA and Matt Osmond FTIA also represented the Taxation Institute at the NTLG Finance & Investment meeting on Tuesday, 20 July 2010. Committee members discussed the content of a proposed tax determination on whether there is an effectively non contingent obligation under Division 974 for limited recourse debt. The ATO provided an update on their compliance activities. In particular, the ATO said that they are conducing a number of risk reviews and audits focussing on financing arrangements between stapled entities, in particular the application of section 974-80. The ATO indicated that they may draft a tax determination or ruling outlining their concerns with the arrangements.

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