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Draft PSLA 2843 - Exercise of the Commissioner’s discretion under Section 109RB presentation


This presentation covers:

  • overview of Section 109RB
  • administrative law principles
  • does Division 7A apply?
  • administrative review.


Author profiles

Andrew O'Bryan CTA
Photo of author, Andrew O'BRYAN Andrew is a senior Tax Partner at Hall & Wilcox Lawyers. He has nearly 35 years experience giving expert tax advice to private business and wealthy family groups. He has particular expertise in the tax aspects of succession planning and in managing complex disputes with the ATO. - Current at 04 January 2018
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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 Division 7A - What you need to know .

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Individual sessions

Draft PSLA 2843 - Exercise of the Commissioner's discretion under Section 109RB

Author(s):  Mathew UMINA,  Andrew O'BRYAN

Materials from this session:

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