Source: The Tax Specialist Journal Article
Published Date: 1 Apr 2017
The ATO released two controversial documents affecting infrastructure investments early this year. The first document was TA 2017/1, which highlights the ATO's concern with stapled structures that attempt to re-characterise trading income into passive income to attract concessional tax treatment. The second document was the draft Privatisation and infrastructure " Australian federal tax framework, which updates and expands on documents previously released by the ATO. Both documents have caused a degree of disquiet to investors and advisers who are grappling with what the ATO's stated positions mean to their investments. The focus of this article is on the concept of control for the purposes of s 102N(1)(b) in Div 6C. The authors hope that an appreciation of the issues currently arising might inform the process of developing a framework that will ensure that appropriate levels of taxation are paid while having a minimal effect on business confidence and efficiency.
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