ITAA 1936 s IVA

Transfer pricing issues related to inbound distribution arrangements

Allocation of professional firm profits - ATO compliance approach

Intangibles arrangements

Personal services businesses and Part IVA of the Income Tax Assessment Act 1936

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

Application of General Anti-Avoidance Rules

Administering general anti-abuse rules, such as a principal or main purposes test, included in any of Australia's tax treaties

Income tax: Interest Withholding Tax Exemption - for the purposes of subsection 128F(5) of the Income Tax Assessment Act 1936 , when will a company be taken to have the requisite knowledge or suspicion that the debenture or an interest in the debenture was being, or would later be, acquired by an associate?

Income tax: what are the results for income tax purposes of entering into a partnership of the type described in Taxpayer Alert TA 2002/4?

Income tax: will Part IVA of the Income Tax Assessment Act 1936 always apply if a business (including a personal services business) pays superannuation contributions that are considerably in excess of the value of the services provided by the employee?

Income tax: can section 160ZZZJ of Part IIIB of the Income Tax Assessment Act 1936 apply to interest entered in the accounting records of an Australian branch of a foreign bank if the interest relates to a borrowing the branch has obtained from a third party?

Income tax: is the deductibility of compound interest determined according to the same principles as the deductibility of other interest?

Income tax: is interest on a loan fully deductible under section 8-1 of the Income Tax Assessment Act 1997 when the borrowed moneys are settled by the borrower on trust to benefit the borrower and others?

Income tax: does the disposal or termination of an interest in a non-forestry managed investment scheme which arises as a result of circumstances outside the control of the taxpayer result in the denial of deductions previously allowed under paragraph 8-1(1)(b) of the Income Tax Assessment Act 1997 in respect of your contributions to the scheme?

Income tax: can Part IVA of the Income Tax Assessment Act 1936 apply to an asymmetric swap scheme?

Income tax: treaty shopping - can Part IVA of the Income Tax Assessment Act 1936 apply to arrangements designed to alter the intended effect of Australia's International Tax Agreements network?

Income tax: can Part IVA of the Income Tax Assessment Act 1936 apply to an employee savings plan as described in Taxpayer Alert TA 2008/13?

Income tax: can Part IVA of the Income Tax Assessment Act 1936 apply to a salary deferral arrangement as described in Taxpayer Alert TA 2008/14?

Income tax: is 'Australian source(s)' in subsection 6-5(3) of the Income Tax Assessment Act 1997 dependent solely on where purchase and sale contracts are executed in respect of the sale of shares in an Australian corporate group acquired in a leveraged buyout by a private equity fund?

Income tax: can Part IVA of the Income Tax Assessment Act 1936 apply to a scheme designed to convert otherwise assessable interest income into non-assessable non-exempt dividends?