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Taxation of foreign exchange gains and losses for corporates paper


In a volatile exchange rate environment, it is important that taxpayers understand the complex rules governing the taxation of foreign exchange gains and losses. This paper provides an overview of the manner in which the disparate regimes in Division 230 (TOFA), Division 775, the translation rules in Division 960 and “legacy” regimes interact. It also covers some practical case studies aimed at non-financial institution corporate taxpayers who may have:

  • entered into financing arrangements in foreign currency;
  • entered into foreign currency derivatives;
  • made investments in foreign currency denominated assets;
  • made outbound investments in foreign currency.

Author profiles

Abdol Mostafavi CTA
Photo of author, Abdol MOSTAFAVI Abdol Mostafavi is a Partner in the Business Tax Services group at Deloitte, and is based in Sydney. Abdol has over 21 years of experience in corporate and international tax, having advised a wide range of multinational clients in the financial services, real estate, transport, infrastructure services, and utilities sectors. - Current at 10 June 2019
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Craig Marston CTA
Craig Marston, CTA, is a member of KPMG’s tax practice. Craig advises on a range of tax matters for various Australian listed and multinational groups. Craig’s experience includes working with several Australian banks and life/funds management groups, as well as various listed and foreign private property trusts. More recently Craig’s particular interest is working with “start-ups” to realise their international expansion ambition. - Current at 09 July 2018
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