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TOFA and hedging paper


This paper covers the application of the TOFA hedging method to hedging of net investments in foreign operations, exempt dividend income and interest rate hedges through worked examples to illustrate:

  • identification of the appropriate hedged item
  • the contemporaneous documentation required
  • how effectiveness is tested
  • what the different book and tax treatment means for the ineffective portion
  • other differences between book and tax treatment
  • what happens when things change: effectiveness, consolidation and accounting changes.

Author profile:

Mathew Umina
Mathew is an Assistant Commissioner in the Public Groups & International area of the ATO. Mathew has been with the ATO for more than 15 years and has held several senior roles in corporate tax and international areas, as well as the SME and high wealth individuals area. This has included several years working on the design and implementation of the TOFA regime, and more recently as the ATO delegate and Competent Authority to the JITSIC Taskforce in London. Mathew is currently responsible for the ATO's Energy and Resources Industry Strategy, as well as a Competent Authority for mutual agreement procedure and advance pricing agreements casework. Mathew also works in the Technical Resolution area, working on complex and strategically significant cases in the Public Groups market. Current at 30 April 2015

This was presented at Financial Services Taxation Conference 2009.

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