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Written by practitioners for practitioners Taxation in Australia is continually ranked as Australia's leading tax journal.

Published 11 times per year, the 'blue journal', as it is affectionately known, is available exclusively to members.

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Articles from the current issue:

  • Obtuse s 99B and offshore trusts

    shopping_cart Add to cart 01 Apr 2021

    Offshore trusts are subject to uncertain income tax rules, which means that they attract interpretations that depart from the policy intent of trust taxation. This is problematic and the issue should not be sidestepped because offshore trusts are seen as a murky area. This article argues that there are many legitimate situations where a person will interact with an offshore trust and the taxation should be clear. Section 99B of the Income Tax Assessment Act 1936 (Cth) is one of the more problematic aspects of offshore trust taxation. This article considers what the section is trying to achieve and challenges the view on its operation taken by the Commissioner in TD 2017/24.

  • Inbound interest-free loans: Part 1

    shopping_cart Add to cart 01 Apr 2021

    Interest-free loans are typically drafted as “debt interests” for the purposes of Div 974 of the Income Tax Assessment Act 1997 (Cth) but are not included in the borrower’s thin capitalisation calculations due to there being no interest expense. While interest-free loans are a common funding instrument and appear to be simple, many complexities in relation to their tax treatment can arise. The debt/equity characterisation is often more complex than anticipated due to the breadth of the related scheme provisions, as well as the reconstruction provisions in the transfer pricing rules. Further, the treatment of an interest-free loan for thin capitalisation has been thrown into doubt due to the ATO’s conclusion in TD 2019/12 that a wide variety of costs can be “debt deductions” —if any of these costs are attributable to an interest-free loan, the loan can be included in the borrower’s adjusted average debt.

  • High wealth private groups: Risk reviews

    shopping_cart Add to cart 01 Apr 2021

    The ATO has turned its focus to high wealth private groups (HWPGs) with the implementation of the Next 5,000 tax performance program. Every HWPG will be reviewed over the next four years. This article summarises what HWPGs can be doing now in preparation for a review. This includes identifying risks, getting evidence together to support the positions taken, and considering whether a voluntary disclosure of any errors is necessary. It will also include ensuring that there is a formal documented tax governance policy in place. There is a recognition that this does not mean a policy of the kind that the Commissioner of Taxation requires of large corporates. However, HWPGs are expected to have tax governance policies. High wealth private groups and their advisers are encouraged to take the opportunity to get themselves ready so that they avoid exposure to an audit or ongoing ATO reviews because of a lack of confidence in taxpayer systems.

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