Finance Investment TOFA

TOFA - A new world of economic substance?

Source: QLD

Published Date: 13 Feb 2013

 

Sorry, this is subscriber only content.

If you're not yet a subscriber, to gain access to this material and much more - Subscribe Now.

Already a Subscriber? Login now

Already a Subscriber? Login now

At its essence, TOFA attempts to systematically align the tax treatment of financial arrangements towards their economic substance rather than their legal form.

This paper examines:

  • how do the economic substance provisions work in practice?
  • when does the economic substance approach not apply in practice, i.e. what might be the limits of this economic substance approach?

Issues considered include:

  • economic substance under accounting principles
  • interactions with other parts of the Act that impose non-economic substance-based approaches
  • impact of tax character on substance-based analyses
  • deliberate design features in Div 230 that move away from economic substance
  • consideration of the synthetic disposal and non-disposal rules.

Individual Session

TOFA - A new world of economic substance?

Author(s): Phillip Cole

Details

  • Published By: Phillip Cole
  • Published On:13 Feb 2013
  • Took place at:Hyatt Regency Sanctuary Cove, Gold Coast

The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))

("TTI")

The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.

Tags

Finance Investment TOFA 2013

Share this page