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.
Philip is a barrister at the Victorian Bar practising in federal and state taxation and superannuation. He acts for both taxpayers and revenue authorities and has appeared in a number of leading cases in these fields. Philip is also the author of Bender’s Australian Stamp Duties, a book published by The Tax Institute dealing with stamp duty in all Australian jurisdictions.
- Current at
26 June 2019