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Beware 47A!

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.

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Philip BENDER

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