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TOFA 3 & 4: Practical implications for non-financial institution taxpayers


With the gaining of Royal Assent the long awaited TOFA rules are now a reality. Most business taxpayers will need to make choices on how the rules will apply to them and what options they have. This article explores some of the practical implications of the legislation and in particular addresses the issues relevant to non-financial institution taxpayers. An understanding of these implications should assist taxpayers with their understanding of the rules and their potential application. There are still a number of uncertainties with the legislation but the best way to ascertain their impact is the practical application to real situations.

Author profile:

Neil Ward FTI
Neil is a Partner at Deloitte. Neil has more than 25 years experience advising on tax. During this period he has advised on most aspects of corporate taxation both from an Australian and International perspective. Neil has had significant experience with tax consulting to the banking and finance sector. Neil is recognised as one of the leading tax advisers on financial arrangements, foreign exchange, thin capitalisation and infrastructure transactions and has been actively involved in the tax reform of financial arrangements. Current at 01 June 2009 Click here to expand/collapse more articles by Neil WARD.
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