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AMIT regime implementation – where are we at?


After some decades of grappling with applying the “old” rules of Div 6 of the Income Tax Assessment Act 1936 to modern-day widely held trusts, industry, at long last, got its wish … on 5 May 2016, the attribution managed investment trust (AMIT) regime was enacted. The AMIT regime is the culmination of a Board of Taxation recommendation for “a separate taxation regime for qualifying MITs” and extensive industry consultation. The regime seeks to codify much of the industry practice and administrative concessions that had to emerge to fit the taxation of managed investment trusts into Div 6. This article considers some key aspects and design features of the new regime and, where appropriate, attempts to bring the regime to life with worked examples.

Author profile

Craig Marston CTA
Craig Marston, CTA, is a member of KPMG’s tax practice. Craig advises on a range of tax matters for various Australian listed and multinational groups. Craig’s experience includes working with several Australian banks and life/funds management groups, as well as various listed and foreign private property trusts. More recently Craig’s particular interest is working with “start-ups” to realise their international expansion ambition. - Current at 09 July 2018
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