ATO: Private Wealth – withholding tax on overseas royalties

ATO: Private Wealth – withholding tax on overseas royalties

February 24, 2022

The ATO’s International Risk for Private Groups Program has launched a campaign focusing on non-resident withholding tax relating to royalty expenses paid overseas for the 2019 and 2020 ...Read More Read More

ATO: Trusts Tax Avoidance Taskforce

February 24, 2022

The ATO have released information on its Tax Avoidance Taskforce – Trusts, which targets higher risk trust arrangements in privately owned and wealthy groups. The ATO Trusts taskforce ...Read More Read More

ATO: Division 7A and concern with unit trust arrangements

February 24, 2022

The ATO have raised concerns about a number of arrangements involving unpaid present entitlements and unit trusts that may have implications under Division 7A. The ATO have identified ca...Read More Read More

ATO: Division 7A and UPEs

February 24, 2022

For unpaid present entitlements (UPEs) on or after 1 July 2022, the Commissioner's view in Draft Taxation Determination TD 2022/D1 is that even if not converted to an ordinary loan, a UP...Read More Read More

ATO releases s100A and UPE draft guidance

February 24, 2022

The ATO has released a package of draft advice and guidance products, setting out its evolving view on the tax treatment of: trust entitlements arising out of reimbursement agreements u...Read More Read More

Commercial debt forgiveness: love and affection exclusion finalised

February 17, 2022

Taxation Determination TD 2022/1 finalises the ATO's position on the "natural love and affection" exclusion in the commercial debt forgiveness rules. The key point in TD 2022/1 is that the ...Read More Read More

Reimbursement arrangement s 100A

February 17, 2022

The Commissioner has lodged a notice of appeal to the Full Federal Court from the decision in Guardian AIT Pty Ltd ATF Australian Investment Trust v FCT [2021] FCA 1619. The Federal Cou...Read More Read More

High Court rules on employee vs independent contractor distinction

February 17, 2022

The High Court has made two rulings in relation to the distinction between employees and independent contractors. In Construction, Forestry, Maritime, Mining and Energy Union & Anor v ...Read More Read More