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The "new" Part IVA paper

Published on 07 Nov 13 by NATIONAL DIVISION, THE TAX INSTITUTE

The form of the government’s “new” Part IVA is now known and it also appears that there will be a renewed focus by the ATO on the possible application of PartIVA to transactions undertaken by SMEs that have regard to the tax outcomes. It will be critical for advisers to understand the changes and factor them into the advice provided.

This paper examines:

  • do the amendments reflect a change in the policy of Part IVA and specifically, does the dominant purpose test remain untouched?
  • the operation and impact of the introduced “tax effects” element resulting in a new approach to assessing the “alternative postulates”
  • does the alternative postulate need to be reasonable any longer?
  • what is happening to the concept of “scheme”?
  • the key issues to consider when providing tax structuring advice.

Author profile

Grant Wardell-Johnson CTA
Photo of author, Grant WARDELL-JOHNSON Grant is the Lead Tax Partner of the Economics and Tax Centre at KPMG. Grant has a background in providing tax advice relating to international and domestic tax structuring, international cross-border acquisitions and initial public offerings. Grant now leads the thought leadership on tax policy and consultation on new law, including KPMG’s response to base erosion and profit shifting (BEPS) and the OECD Action Plan. He is Co-Chair of the National Tax Liaison Group, an Adviser to the Board of Taxation, a member of the KPMG Global BEPS Steering Group and the KPMG Responsible Tax Group. He is KPMG Global Partner Champion for Geopolitics & Tax. He is an Adjunct Professor in Taxation and Business Law at the UNSW and an Honorary Fellow of the University of Western Australia. - Current at 25 February 2021
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This was presented at 21st National Tax Intensive .

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