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Top TOFA issues that have slipped under the radar presentation


The TOFA regime has now been law for over two years, and in this time there have been many practical issues identified. Many of these have been resolved through consultation and amendment to the law, however there are a number of key issues that remain on the agenda for review. This presentation explores some of the practical issues that corporates face in applying TOFA as well as looking at the implications of more recent amendments to the law.

Of particular focus, the presentation discusses the:

  • scope of the financial arrangement concept
  • book to tax differences that arise in practice
  • interaction of the tax consolidation and TOFA rules
  • benefits and pitfalls of the hedging method and the changes on the horizon
  • ATO compliance and reviews.

Author profiles

Rhys Manley
Rhys joined the Australian Tax Office in November 2009. He is a Law interpretation Director in the Technical Leadership Group (part of Large Business and International). As a member of this group, Rhys provides interpretative advice and support to compliance teams in relation to the Taxation of Financial Arrangements Stages 3 & Measure. Prior to joining the ATO, Rhys worked in the Finance and Strategy Unit in the Business Tax Division in the Australian Treasury. - Current at 01 December 2012
Michael Muncaster
Michael Muncaster, Director, PwC has over 15 years' experience across accounting and taxation services. Specialising in banking and financial services for the past 8-10 years, working with banks and financial services business in Australia, United Kingdom and Europe. More broadly, Michael's experience includes undertaking tax due diligence for non-bank financial institutions, advising on the taxation of financial arrangements (TOFA), withholding tax, capital instruments and thin capitalisation. Michael has worked on a number of TOFA implementation projects and reviews. - Current at 23 October 2012


Individual sessions

Top TOFA issues that have slipped under the radar

Author(s):  Michael MUNCASTER,  Rhys MANLEY

Materials from this session:

Further details about this event:


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