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Legislation
ATO documents that consider TAA 1953 s IVAAA
2,032 documents
The New Tax System: the requirement to get an ABN for PAYG purposes if you let out a residence
Petroleum resource rent tax: effects of transferring an interest in an exploration permit or retention lease
Freedom of Information Act 1982. Taxation Rulings - Pre 1 December 1982 Series (Referred to for convenience as conversion rulings)
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - does the definition of the term 'debenture' include an individual share or interest in a debenture?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - when is a non-resident borrowing subsidiary treated as a 'resident' for the purposes of the tax law of a country other than Australia?
Income tax: withholding tax avoidance - do the withholding tax avoidance provisions of Part IVA and, in particular, section 177CA of the Income Tax Assessment Act 1936 apply to a decision by a company to establish a programme for the issue of debentures in respect of which interest is exempt from interest withholding tax pursuant to the operation of section 128F?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - for the purposes of the public offer test in paragraph 128F(3)(a) (the 'first public offer test'): (a) are pension funds and other 'qualified institutional buyers' considered to be carrying on the business of providing finance, or investing or dealing in securities? (b) what is required of a company to establish that the persons to whom the debentures are offered are carrying on business in the manner required by the legislation?(c) when is a company taken to know or suspect that such a person is an associate?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - when is it reasonable for a company to regard the person to whom a debenture is offered as either 'having acquired debentures in the past' or 'being likely to be interested in acquiring debentures' for the purposes of the public offer test in paragraph 128F(3)(b)?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - for the purposes of the third public offer test in paragraph 128F(3)(c):(a) what is required to establish that a debenture has been offered for issue as a result of being accepted for listing? (b) does the issue of a debenture satisfy the public offer test if the listing of the debenture by a stock exchange takes place following the issue where an agreement exists with the dealer, manager or underwriter requiring listing to take place?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - does the public offer test in paragraph 128F(3)(d) require a company to demonstrate that negotiations in respect of a particular debenture actually resulted from negotiations being initiated publicly in electronic form?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - does the sole business test in paragraph 128F(8)(b) allow the borrowing subsidiary to enter into credit enhancements and swap arrangements in respect of finance raised for the purposes of the parent company?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - for the purposes of the fifth public offer test, in paragraph 128F(3)(e), in what circumstances is a debenture taken to be 'offered for issue'?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - does an issue of a debenture fail the public offer test in subsection 128F(5) if an associate of the company that issued the debenture takes a security interest over the debenture?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - for the purposes of the exemption exclusion in subsection 128F(6), when does a known associate of the company who is acting in the capacity of a dealer, manager or underwriter in relation to the placement of a debenture, and who receives interest, attract the exclusion?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - when is a company taken to have the requisite knowledge or suspicion that interest was paid to an associate for the purposes of subsection 128F(6)?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - is subsection 128F(10) the only method by which a global bond may satisfy the public offer test?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - does section 128F apply to debentures under which the yield is determined by a variable indexation factor rather than by being fixed?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - how may a company satisfy the introductory requirements in paragraphs 128F(3)(a) and 128F(3)(b) that a debenture must be offered on a 'debenture by debenture' basis?
Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - does the exemption from interest withholding tax in section 128F extend to payments made by a guarantor to a lender on behalf of a borrower who defaults?
Income tax: is a reward received under a 'consumer loyalty program' that results from private expenditure assessable?