ITAA 1936 s 7A

Restructures and the thin capitalisation and debt deduction creation rules - ATO compliance approach

Operation of Division 7A of the Income Tax Assessment Act 1936 on loans that have become statute barred

Compendium

Income tax: consolidation: Division 7A: if a private company, as a member of a consolidated group, makes a payment, a loan or forgives a debt to a shareholder (or shareholder's associate), that is also a member of the consolidated group, does the single entity rule in section 701-1 of the Income Tax Assessment Act 1997 prevent the application of Division 7A of the Income Tax Assessment Act 1936 to the transaction?

Compendium

Income tax: when is the shortfall interest charge incurred for the purposes of paragraph 25-5(1)(c) of the Income Tax Assessment Act 1997 ?

Income tax: is the 'dividend access share' arrangement of the type described in this Taxation Determination a scheme 'by way of or in the nature of dividend stripping' within the meaning of section 177E of Part IVA of the Income Tax Assessment Act 1936?

Compendium

Income tax: disregarding certain payments under section 109R of the Income Tax Assessment Act 1936 in determining how much of a loan has been repaid in situations where notional loans are involved

Dividend Stripping / Distribution of Surplus Profits Arrangements

Arrangements designed to avoid the operation of Division 7A through the use of a Corporate Limited Partnership

Salary Deferral Arrangements

Australian resident entities creating false deductions and/or concealing income through arrangements with promoters based in Vanuatu.

Private company loan arrangement to obtain tax-free distributions and avoid deemed dividends

Australian resident entities using promoted tax schemes in Samoa to claim purported deductions and conceal income or assets

The use of an unrelated trust to access funds of a private company in an attempt to circumvent Division 7A

Loans to members of companies limited by guarantee and the operation of Division 7A

Accessing private company profits through a dividend access share arrangement attempting to circumvent taxation laws

Arrangements to circumvent Division 7A of the Income Tax Assessment Act 1936 through the guaranteeing by private companies of third-party loans

Compendium