Compendium
Relying on this Compendium This Compendium of comments provides responses to comments received on Draft Taxation Determination TD 2023/D2 Income tax: aggregated turnover and connected entities – Commissioner's discretion that an entity does not 'control' another entity. It is not a publication that has been approved to allow you to rely on it for any purpose and is not intended to provide you with advice or guidance, nor does it set out the ATO's general administrative practice. Therefore, this Compendium does not provide protection from primary tax, penalties or interest for any taxpayer that purports to rely on any views expressed in it.
Relying on this Compendium This Compendium of comments provides responses to comments received on Draft Taxation Determination TD 2023/D2 Income tax: aggregated turnover and connected entities – Commissioner's discretion that an entity does not 'control' another entity. It is not a publication that has been approved to allow you to rely on it for any purpose and is not intended to provide you with advice or guidance, nor does it set out the ATO's general administrative practice. Therefore, this Compendium does not provide protection from primary tax, penalties or interest for any taxpayer that purports to rely on any views expressed in it.
Summary of issues raised and responses
Issue number Issue raised ATO response 1 Paragraphs 43 and 44 (Example 5) of the final Determination should say "control percentage...of at least 40%" and "a control percentage...of at least 40%. Agreed. Paragraphs 43 and 44 have been modified in the final Determination.
Issue number | Issue raised | ATO response
1 | Paragraphs 43 and 44 (Example 5) of the final Determination should say "control percentage...of at least 40%" and "a control percentage...of at least 40%. | Agreed. Paragraphs 43 and 44 have been modified in the final Determination.
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Compendium
The ATO published responses to 1 submission on this ruling in TD 2023/5EC. Outcome labels are heuristic — read the ATO response for the detail.
1Paragraphs 43 and 44 (Example 5) of the final Determination should say "control percentage...of at least 40%" and "a control percentage...of at least 40%.accepted
ATO response
Agreed. Paragraphs 43 and 44 have been modified in the final Determination.