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Draft Taxation Determination TD 2009/D17 - Income tax: treaty shopping – can Part IVA of the Income Tax Assessment Act 1936 apply to arrangements designed to alter the intended effect of Australia’s International Tax Agreements network?

Published on 04 Feb 10 by THE TAX INSTITUTE

The Draft TD refers to ‘Private Equity'. The Professional Bodies take this as a reference to the practice of many investors including superannuation and pension funds, insurance funds, mutual funds, sovereign funds and other institutional and non-institutional investors together (in collective investment vehicles) to make specific investments or classes of investment through pooling of investment capital allocated for that purpose. Private equity investment does not involve merely investment banks investing on their own account. Given the wide ambit of the potential application of the Draft TD, a more accurate and descriptive term for such investment activity may be Pooled Fund. That term is used in this submission.

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NATIONAL INSTITUTE OF ACCOUNTANTS
Current at 19 November 2004
 
TAXPAYERS AUSTRALIA INC
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TAXATION INSTITUTE OF AUSTRALIA
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ICAA
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CPA AUSTRALIA
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