This paper covers:
- how the non-arm’s length income rules apply (and don’t apply) to related party dealings, dividends from private companies and distributions from trusts?
- what is a fixed entitlement in a trust for the non-arm’s length income rules?
- whether a nil interest loan under a limited recourse borrowing arrangement will trigger the non-arm’s length income rules?
- whether the non-arm’s length income rules apply to capital gains and distributions?
- what principles come out of the recent cases on special/non-arm’s length income?