Source: Taxation In Australia Journal Article
Published Date: 1 Jul 2020
The ATO's approach to central management and control (CMAC) in TR 2018/5 and PCG 2018/9 introduces a new controversy into corporate residency by potentially treating a single board meeting as the exercise of CMAC in multiple jurisdictions. This article argues that such an approach is inconsistent with the foundation of CMAC first set out in De Beers case, and followed in previous dual CMAC decisions such as the Union Corporation case, that a company resides where CMAC actually abides and the real business of the company is carried on.
Capital allowances - A comprehensive update on the latest developments & opportunities - Presentation 01 Apr 2009
Capital versus revenue: the sun never sets - Presentation 16 Apr 2008
Important corporate funding and distribution developments - Presentation 18 Apr 2007
Capital structuring for corporate groups - Presentation 07 Oct 2005
In Search of the True Demerger: Boundary Issues with Division 125 - Presentation 22 Aug 2003
In Search of the True Demerger: Boundary Issues with Division 125 seminar - Paper 22 Aug 2003
Some Issues with Demerger Relief - Journal 01 Oct 2002
Tax relief for demergers - Paper 12 Sep 2002
Tax relief for demergers - Presentation 12 Sep 2002
The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The Tax Institute
(ABN 45 008 392 372 (PRV14016))
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.