Published on 01 Apr 07
by "THE TAX SPECIALIST" JOURNAL ARTICLE
Section 47A is an anti-avoidance provision that deems certain benefits provided by Controlled Foreign Companies to other entities to be dividends. The ATO has recently released Draft Taxation Determination TD 2007/D1 which outlines the application of section 47A to situations where a CFC provides these covered benefits to another associated CFC. This article analyses the ATO’s reasoning and conclusions in the Draft Determination.
Current at 07 December 2011
Click here to expand/collapse more articles by Philip BENDER.