ITAA 1997 s 974

Distribution Statements: allocation of franking credit to frankable distribution

Withholding Tax: income that is equivalent to the payment of interest on a loan

Withholding Tax: dividends paid in respect of redeemable preference shares - rate of withholding tax determined under the United States Convention

Distributions treated as interest - are they 'determined with reference to profits' under Article 11(9)(a) of the United States Convention

Benchmark rate of return: Mandatorily Redeemable Preference Share (MRPS)

Non-portfolio dividends: returns on redeemable preference shares - debt interests

Consolidation: single entity rule and issue of non-share equity

Consolidations: single entity rule and payment of non-share dividends

Frankable distributions and non-share dividends

Imputation: benchmark rule and non-share equity interests

Taxation of financial arrangements: interaction between Division 974 of the Income Tax Assessment Act 1997 (ITAA 1997) and the definition of a financial arrangement (equity interest or right or obligation in relation to an equity interest) in Division 230 of the ITAA 1997

Taxation of financial arrangements: application of subsection 230-15(5) of the Income Tax Assessment Act 1997 to a dividend on a debt interest

Taxation of financial arrangements: timing of deductions under subsection 230-15(4A) of the Income Tax Assessment Act 1997

ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions

ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions

Income tax: can the assignment of an intra-group debt or income stream to an entity that is not a member of the consolidated group give rise to a debt interest for the head company of the group under Division 974 of the Income Tax Assessment Act 1997?

Income tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997, if the issuer of an interest bearing instrument can change the rate of interest that will become payable to any rate (including zero) that it chooses at its sole discretion, does the issuer have an 'effectively non-contingent obligation' to provide 'financial benefits' as interest payments from the time that a change in the interest rate could take effect?

Income tax: does subsection 974-135(1) of the Income Tax Assessment Act 1997 only apply to a legally enforceable obligation?

Income tax: where a taxpayer has supplied or acquired property under an international agreement and that gives rise to a debt interest or an equity interest as defined for the purposes of Division 974 of the Income Tax Assessment Act 1997, does Division 974 bear upon the characterisation to be adopted for the purposes of the application of Division 13 of Part III of the Income Tax Assessment Act 1936 to the transaction?

Income tax: can the debt and equity rules in Division 974 of the Income Tax Assessment Act 1997 limit the operation of the transfer pricing rules in Subdivision 815-B of the Income Tax Assessment Act 1997 ?