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

Published on 01 Jun 09 by "THE TAX SPECIALIST" JOURNAL ARTICLE

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 Ward FTIA leads the Deloitte Australian Financial Services Tax Group. He has more than 30 years experience in advising in tax. Prior to joining Deloitte in March 2000, Neil spent 12 years with the ANZ Banking Group in Australia and the United Kingdom. Neil is recognised as one of the leading tax advisers on financial arrangements, foreign exchange, thin capitalisation, capital management, withholding tax and infrastructure transactions. - Current at 05 October 2012

More by Neil WARD

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• Taxation of Financial Arragements Workshop - 27-October-1999
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• Break out - IIB : DTA's/CFC's and FX - 19-November-1997
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