The TOFA legislation received Royal Assent six months ago and early electing taxpayers may in
some cases be already subject to the new rules. There is still time before the first TOFA elections need to be made.
This paper covers a number of practical issues that have become relevant in determining the potential impact of TOFA and is intended to help with your decisions on the various elections available. It includes a practical analysis supported by case studies covering:
- a suggested approach to determining the preferable TOFA position
- is tax hedging as beneficial as it appears and how is it achieved?
- when would you consider the accounting based elections?
- TOFA issues still under consultation.