The Tax Institute Submission | Joint Submission: Superannuation Non-Arm's Length Income Rules

Author: The Tax Institute

Published Date: 3 Feb 2022


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The introduction of the non-arm's length expenditure (NALE) rules, and the ATO's interpretation of these rules, as published in the recently finalised Law Companion Ruling LCR 2021/2, will have far reaching and, it is submitted, significant harmful consequences; it is difficult to imagine that such outcomes were intended. These rules apply with effect from 1 July 2018, including with respect to income derived as a result of an arrangement entered into prior to that date.


  • Published By:The Tax Institute
  • Published On:3 Feb 2022

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