Service trusts paper

Published on 14 Sep 05 by VICTORIAN DIVISION, THE TAX INSTITUTE

Topics covered in this paper include:

• what is a Phillips type service trust?
• what the Commissioner said about Phillips type service arrangements prior to the draft ruling
• how does the draft ruling and guidance document impact upon Phillips type service trusts?
• what the guidance document says about the key characteristics of an allowable service trust?
• what characteristics should be avoided in a service trust?
• are there any safe harbours?
• is it necessary to undertake transfer pricing review to determine service fees?
• how important is documentation?
• retrospective impact of the draft ruling
• planning approach - what needs to be done NOW!

Author profile

Peter Murray CTA-Life

Peter Murray is a Senior Tax Partner at KPMG and KPMG Tax Law and past President of The Tax Institute. Peter specialises in advising clients on a broad range of corporate tax issues and has experience in domestic and international tax matters including advising on mergers and acquisitions, business tax reform, capital structures and restructuring international corporate groups. Peter also focuses on managing tax disputes and providing legal tax advice. - Current at 19 May 2017

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