Compliance program 2011-12

Restructuring by professional firms

Professional firms play a significant role both as taxpayers and as intermediaries within the tax system. We have observed considerable restructuring among professional firms, particularly by accounting and legal practices.

We have commenced several reviews where we have noticed discretionary trusts being added or substituted as partners, and where the income of practitioners has dropped significantly post-restructure. We seek to understand the drivers of the restructure and whether the legal form of the new structure has been followed in practice. Where there is evidence that the legal form of the structure differs from that which has been entered into by the taxpayers, we will undertake a review to understand the commercial drivers of such restructures.

Sections within Small-to-medium enterprises

• Private groups
• Highly wealthy individuals
• Wealthy Australians
• $100 million - $250 million segment
• Employer obligations
• Lodgment compliance
• Trusts
• Phoenix arrangements
• Overseas interests and international dealings
• Division 7A
• Capital gains tax
• Foreign residents
• Capital and revenue losses
• Restructuring by professional firms
• Fringe benefits tax
• Taxation of financial arrangements (TOFA)
• Small business and general business tax break
• Goods and services tax (GST)
• Refund integrity
• Property
• Retirement villages
• Integrity of business systems
• Financial supplies
• International and cross-border transactions
• GST serious evasion
• Excise
• Excise equivalent goods
• Tax reporting of exports including excisable goods
• Wine equalisation tax
• Alternative fuels
• Superannuation
• Managing business tax debt