ITAA 1936 s IVA

Management of Significant Technical Issues

Referral of interpretative issues to Centres of Expertise for the creation of the precedential ATO view, and early engagement of internal technical specialists in active compliance cases

Aggressive tax planning end-to-end process.

Application of the promoter penalty laws (Division 290 of Schedule 1 to the Taxation Administration Act 1953 ) to promotion of tax exploitation schemes

ATO's Advance Pricing Arrangement Program

Income tax: what characteristics of financial arrangements regarding investment in Australian films preclude a Division 10B tax concession?

Income tax: can section 177EA of the Income Tax Assessment Act 1936 apply to the issue of 'dollar value' convertible notes of the type described in this Taxation Determination?

Income tax: where there is no excess debt under Division 820 of the Income Tax Assessment Act 1997 can the transfer pricing provisions apply to adjust the pricing of costs that may become debt deductions, for example, interest and guarantee fees?

Income tax: (a) are credits for United Kingdom interest withholding tax paid allowable under Article 22.1(a) of the 2003 United Kingdom Convention to an Australian resident financial institution which enters into an arrangement of the kind described in Taxpayer Alert TA 2007/3; and (b) would the Commissioner consider the application of Part IVA of the Income Tax Assessment Act 1936 to the arrangement?

Notice of Withdrawal - Income tax: (a) are credits for United Kingdom interest withholding tax paid allowable under Article 22.1(a) of the 2003 United Kingdom Convention to an Australian resident financial institution which enters into an arrangement of the kind described in Taxpayer Alert TA 2007/3; and (b) would the Commissioner consider the application of Part IVA of the Income Tax Assessment Act 1936 to the arrangement?

Income tax: in what circumstances is an asset of a complying superannuation fund a segregated current pension asset under section 295-385 of the Income Tax Assessment Act 1997?

Income tax: application of sections 51, 23AJ, 79D and Part IVA to the deductibility of interest expense of a resident company

Income tax: UBS AG Key employee lending incentive plan

Living Away from Home Allowance - Interposed Company

Deductibility of compound interest on a split loan facility

Deductibility of compound interest on a line of credit facility