| TA 2002/09 - Remote Area Housing Benefit Arrangements |
| This alert describes an arrangement where an employer and its employee enter into a lease arrangement on a residential property either owned or leased by the employee in a remote area and the employee gains tax deductions for their private residence. |
| TA 2003/4 - Assignment of Australian Copyright on Articles Prepared by Non- Resident Authors |
| This Taxpayer Alert describes an arrangement involving a purported assignment of Australian copyright on articles prepared by non-resident authors. It is argued that the payments made to the non-resident authors are not subject to Royalty Withholding Tax |
| TA 2004/9 - Exploitation of the second-hand goods provisions to obtain Goods and Services Tax (GST) input tax credits |
| A GST registered entity acquires goods through a non-taxable supply. The acquiring entity sells the goods to an associated entity, creating a claim for an input tax credit on acquisition of the goods under the second-hand goods provisions. |
| TA 2005/8 - Asset transfer to an offshore structure at below market value with subsequent use to produce income not attributed to the taxpayer for Australian tax purposes |
| Describes an arrangement to reduce exposure to Australian tax by providing goods or services to an offshore structure below market value, which then provides the same goods or services to a third party at market value, paying no Australian tax. |
| TA 2007/6 - Scholarship Trusts and Education Funding Programs |
| This Taxpayer Alert describes an arrangement where a Scholarship Trust is claimed to be established either in Australia or in a foreign country and, in combination with what is described as an 'Education Funding Program', seeks to provide funds to a student which the marketer claims are free of tax. |
| TA 2010/3 - Non market value acquisition of shares or share options by a self-managed superannuation fund |
| This Taxpayer Alert describes an arrangement where an individual nominates their self-managed superannuation fund (SMSF) as the acquirer of shares or share options under an employee share scheme. |
| TA 2009/21 - R&D tax offset abuse through registered research agencies |
| This Taxpayer Alert is concerned with the Research and Development (R&D) tax offset allowable under certain conditions to eligible companies. |
| TA 2008/20 - Foreign residents exploiting asset valuations to avoid capital gains tax |
| This Taxpayer Alert describes certain arrangements where foreign residents seek to avoid capital gains tax from the indirect disposal of Australian real property under Division 855 of the Income Tax Assessment Act 1997. |
| TA 2002/08 - Mutual associations - deductibility of contributions and derivation of income (volume allowances) |
| This alert describes an arrangement where a retailer claims a deduction for volume allowances contributed to a mutual association. The association's expenses are less than the contributions, and the surplus is said to be returned to the retailer tax free. |
| TA 2003/3 - Avoidance of capital gains tax utilising a trust structure |
| This Taxpayer Alert describes an arrangement involving the sale of capital gains tax assets to an arm's length party. The taxable capital gains are streamed to a tax preferred entity and the original owners receive the sale proceeds free of CGT liability. |
| TA 2004/8 - Use of the Going Concern provisions and the Margin Scheme to avoid or reduce the Goods and Services Tax (GST) on the sale of new residential premises |
| This Taxpayer Alert describes an arrangement where an entity sells substantially completed residential units/houses to another entity as a GST-free going concern. When completed, the units/houses are sold as a taxable supply to third parties. |
| TA 2005/7 - Asset transfer to an offshore structure at below market value in anticipation of resale to a third party at market value |
| Describes an arrangement to reduce exposure to Australian tax where an Australian resident taxpayer transfers an asset to an offshore structure below market value. The offshore structure subsequently sells the asset to a third party at market value. |
| TA 2007/5 - Arrangements designed to avoid the operation of Division 7A through the use of a Corporate Limited Partnership |
| This Taxpayer Alert describes arrangements which attempt to circumvent the application of Division 7A of Part III the Income Tax Assessment Act 1936 (ITAA 1936) through the use of what is claimed to be a Corporate Limited Partnership ('CLP'). |
| TA 2008/19 - Foreign residents attempting to avoid Australian capital gains tax by certain |
| This Taxpayer Alert describes certain 'staggered sell down' arrangements designed to result in disregarded capital gains tax where there is an indirect disposal of Australian real property under Division 855 of the Income Tax Assessment Act 1997. |
| (Withdrawn) TA 2010/2 - Circumvention of Excess Contributions Tax |
| The Alert is withdrawn. Following a review of these arrangements, the ATO has concluded that some trust deed clauses may prevent a payment to a trustee of a superannuation fund from forming part of the fund and therefore from being a contribution for excess contributions tax and other purposes. |
| TA 2009/20 - Interest deduction generators involving promoter controlled companies |
| Describes an arrangement which seeks to generate interest deductions for the taxpayer through refinancing a taxpayer's existing home loan and establishing purported investment loans to fund the purchase of shares in companies controlled by the promoter. |
| (Withdrawn) TA 2002/07 Living Away from Home Allowance - Interposed Company |
| This Alert is withdrawn as the risks inherent in the alert have abated. |
| TA 2003/2 - Investment into Foreign Life Insurance Policies |
| This Alert is about borrowing money to invest in a life insurance policy from a tax haven based life insurance company and seeking to earn tax-free income outside Australia on the investment and claiming deductions for interest paid on the borrowings. |
| TA 2004/7 - Use of the Grouping provisions and the Margin Scheme to avoid or reduce the Goods and Services Tax (GST) on the sale of new residential premises |
| This Taxpayer Alert describes an arrangement that uses the grouping provisions and the margin scheme in an attempt to avoid or reduce GST on the sale of new residential premises. |
| TA 2005/6 - Use of an inbound offshore re-invoicing arrangement to avoid or evade Australian tax |
| Describes an arrangement to reduce exposure to Australian tax by using an offshore structure to artificially inflate the price of goods or services. In extreme cases, no actual goods or services may be provided and no third party may actually be involved. |
| TA 2007/4 - Share options granted under an employee share scheme to a related trust |
| This Taxpayer Alert describes an arrangement to avoid tax, through the use of a related trust, by an individual taxpayer in respect of options to acquire shares granted under an employee share scheme. |
| TA 2010/1 - GST - interposing an associated 'financial supply facilitator' to enhance claims for reduced input tax credits for expenses incurred in the course of a company takeover |
| This Taxpayer Alert describes an arrangement that attempts to create or increase an entitlement to a reduced input tax credit (RITC) for an entity that makes a financial supply of acquiring shares in a company as part of a takeover. |
| TA 2009/19 - Uncommercial offshore superannuation trusts |
| Outlines the arrangements that use offshore trust structures (purported to be superannuation funds) attempting to shift funds into Australia in a concessionally taxed manner or substantially defer the time such amounts are subject to tax in Australia. |
| TA 2008/18 - Arrangements to shift foreign business losses into Australian branches or resident entities |
| Describes arrangements within multi-national companies operating through branches, or operating through transactions with foreign associates, which seek to shift deductions for losses from foreign operations into their Australian businesses. |
| TA 2003/1 - Distribution to Superannuation Fund from Interposed Fixed Trust |
| This Alert describes an arrangement where a taxpayer establishes a fixed trust to distribute business profits to their superannuation fund in order to access the concessional tax rate and avoid the aged based deduction limits and superannuation surcharge. |
| TA 2004/6 - Use of the Grouping provisions of the GST Act to avoid Goods and Services Tax (GST) on the sale of new residential premises |
| This Taxpayer Alert describes an arrangement that uses the grouping provisions (specifically an 'internal sale' between GST group members) in an attempt to avoid GST on the sale of new residential premises. |
| TA 2005/5 - Use of an outbound offshore re-invoicing arrangement to avoid or evade Australian tax |
| Describes an arrangement to reduce exposure to Australian tax by providing goods or services to an offshore structure below market value, which then provides the same goods or services to a third party at market value, paying no Australian tax. |
| TA 2007/3 - Income Tax: Foreign tax credit enhanced return bond investment |
| This Taxpayer Alert describes an arrangement where an Australian resident taxpayer seeks to enhance its return on a bond investment, through access to foreign tax credits for withholding tax claimed to be payable under the arrangement. The desired net effect of the arrangement is that neither the bond issuer group, nor the Australian resident taxpayer, bears the economic cost of the tax withheld. |
| TA 2009/18 - Discretionary Option Arrangement |
| This Taxpayer Alert describes an arrangement where an employer attempts to artificially create an up front tax deduction by issuing a discretionary option to employees utilising a trust and round robin cash-flows. |
| TA 2008/17 - Claims for GST refunds beyond four years arising from the reclassification of a previously taxable supply as GST free |
| This Taxpayer Alert describes a situation where a taxpayer seeks to claim a refund four years or more after the end of a tax period on the basis that they incorrectly classified a supply as a taxable supply and they now contend it is GST free. |
| TA 2004/5 - Copyright Transfer Arrangement |
| A taxpayer disposes of its client records in which copyright may subsist to an entity that is part of the same wholly-owned group. That entity then claims a deduction in relation to copyright under the capital allowance provisions. |
| TA 2005/4 - Creation of Goods and Services Tax (GST) input tax credits by barter exchanges |
| A barter exhange uses unlimited trade dollars to buy and sell goods and services in its own right. By buying at commercially unrealistc prices from its members, and ensuring acquisitions continually exceed supplies, they claim significant GST refunds. |
| TA 2007/2 - Employee Entitlement Fund |
| This alert describes an arrangement where an employee seeks to obtain a deduction for contributions purportedly made to an Employee Entitlement Fund on the basis that the contributions are to meet entitlements that may arise in the future for employees. |
| TA 2009/17 - Life insurance bonds issued by tax haven entities |
| This Taxpayer Alert is concerned with life insurance bonds issued from tax haven entities to Australian residents which are designed to circumvent the Australian tax payable under the foreign investment fund measures. |
| TA 2008/16 - Liquidation of entities to avoid the payment of tax liability |
| This Taxpayer Alert describes arrangements whereby taxpayers involved in a previous tax avoidance scheme enter into an arrangement to avoid the payment of the tax liability arising from that scheme by liquidating entities. |
| TA 2002/04 - Personal Services - Partnership Arrangement |
| This Alert is about taxpayers purporting to form a partnership with unrelated taxpayers to recharacterise their individual personal services income as partnership income. Each partner then attempts to split their income with family members. |
| TA 2004/4 - New Zealand Foreign Trust |
| This Taxpayer Alert describes an arrangement where a New Zealand based foreign discretionary trust provides services, at a mark up, to an Australian resident business. |
| TA 2005/3 - Consolidation - Application of the tax cost setting rules to copyright |
| This Alert describes an arrangement where the head company of a consolidated group seeks to claim a capital allowance based on an inflated tax cost setting amount, in relation to any copyright in an asset containing knowledge and/or information. |
| TA 2007/1 - Lease by a charitable institution to an associated endorsed charitable institution designed to gain input tax credits. |
| Describes an arrangement whereby a charitable institution leases its land and buildings to an associated charitable institution so that a supply of residential accommodation qualifies as GST - free. |
| TA 2009/16 - Circumvention of in-house asset rules by self-managed superannuation funds using related party agreements |
| This Taxpayer Alert describes an arrangement where a self-managed superannuation fund enters into an agreement (sometimes referred to as a joint venture agreement) with a related trust to acquire assets such as rental property. |
| TA 2008/15 - Profit washing scheme using a trust and a loss entity |
| This Taxpayer Alert describes arrangements where a taxpayer attempts to minimise tax liability by using tax losses in an unrelated entity. This Alert highlights additional features of concern to arrangements similar to those described in TA 2005/1. |
| TA 2004/3 - Dividend Stripping / Distribution of Surplus Profits Arrangements |
| This Taxpayer Alert describes arrangements involving the transfer of retained earnings and/or current year profits of a company to the shareholders or their associates in a non-taxable form. |
| TA 2005/2 - Prepaid Services Warrant Arrangement |
| This describes an arrangement where for a relatively small cash outlay large losses are created by the taxpayer or their partnership by acquiring prepaid service warrants that may be redeemable for the provision of legal and other professional services. |
| TA 2009/15 - Payment of inflated insurance premiums to a related party |
| This Taxpayer Alert describes an arrangement involving payments of amounts described as insurance premiums which are excessive by reference to the coverage provided and feature no significant transfer of insurance risk. |
| TA 2008/14 - Salary Deferral Arrangements |
| This Taxpayer Alert concerns arrangements where an employee defers salary and wage income. The purpose of the arrangements is to convert salary and wage income to a form that is taxed concessionally or not at all. |
| TA 2004/2 - Avoidance of Goods and Services Tax (GST) on the sale of new residential premises |
| This Alert describes the use of the joint venture provisions to avoid GST on the sale of new residential premises. The arrangement creates an Internal sale and the subsequent sale is claimed to be input taxed and not subject to GST as the units/houses are no longer new residential premises. |
| TA 2005/1 Profit washing scheme using a trust and loss entity |
| This Taxpayer Alert describes an arrangement where the taxpayer seeks to minimise tax payable by restructuring their business so that the income of the business passes through a chain of trusts and on to a loss company. |
| TA 2009/14 - Artificially creating capital losses through default beneficiary arrangement to offset capital gains |
| This Taxpayer Alert describes arrangements where a taxpayer with a current or future capital gain attempts to artificially create capital losses through default beneficiary arrangement to offset capital gains. |
| TA 2008/13 - Employee Savings Plans |
| This Taxpayer Alert describes arrangements involving employee benefit trust structures that attempt to convert salary or wages income into a capital gain. |
| TA 2004/1 - Non-arms length arrangements using Goods and Services Tax (GST) cash / non-cash accounting methods to obtain a GST benefit. |
| This Taxpayer Alert describes non-arm's length arrangements where an entity makes acquisitions from another entity at commercially unrealistic prices to obtain an inflated input tax credit. |
| TA 2009/13 - Managed Investment Schemes: Purported partnership participation |
| This Taxpayer Alert describes an arrangement where a purported partnership is inserted into an investment in an afforestation, agricultural or horticultural Managed Investment Scheme (MIS) in order to generate deductions for the newly inserted partners. |
| TA 2008/12 - Non-cash contributions to superannuation funds |
| This Taxpayer Alert is concerned with arrangements that have features which are designed to allow a member of a superannuation fund to circumvent the new superannuation contributions limits that came into effect from 1 July 2007. The arrangements will mainly involve self-managed superannuation funds, but need not be limited to them. |
| TA 2009/12 - Re-characterising capital losses as revenue losses |
| This Taxpayer Alert describes an arrangement whereby taxpayers seek to re-characterise their shareholding status from that of a long term capital investor to a trader in shares. |
| TA 2008/11 - Land Impairment Trust Arrangement |
| This Taxpayer Alert describes land impairment trust arrangements associated with forestry managed investment schemes. These arrangements involve the sale of land at an impaired value by a member of a group of entities that are treated as a consolidated group for income tax purposes. |
| TA 2009/11 - Retail Premiums paid on unexercised share entitlements |
| This Taxpayer Alert describes arrangements where a company pays shareholders, who have unexercised share entitlements an amount (referred to in this Alert as a 'Retail Premium'), in respect of those unexercised entitlements. |
| TA 2008/10 - Purported prepayment of service fees designed to postpone tax liability |
| This Taxpayer Alert describes an arrangement for the prepayment of service fees from a trading entity to an associated service entity in which the dominant purpose of the arrangement was to secure a deduction in the year of alleged payment rather than in the year any services were provided. |
| TA 2008/9 - Private company loan arrangement to obtain tax-free distributions and avoid deemed dividends |
| This Taxpayer Alert describes an arrangement whereby a shareholder purports to make a repayment of a shareholder loan from a private company via a round robin of endorsed cheques so as to avoid the operation of Division 7A of the Income Tax Assessment Act 1936. |
| TA 2009/10 - Non-commercial use of negotiable instruments involving self-managed superannuation funds |
| This Taxpayer Alert describes arrangements involving non-commercial use of negotiable instruments (usually a promissory note) to pay a benefit from or make a contribution to a self-managed superannuation fund (SMSF). |
| TA 2008/8 - Australian resident entities creating false deductions and/or concealing income through arrangements with promoters based in Vanuatu |
| This Taxpayer Alert describes arrangements through which Australian resident entities, with the help of a promoter in Vanuatu, seek deductions for artificially created expenses and/or establish structures that enable the concealment of income to attempt to avoid or evade Australian tax. |
| TA 2009/9 - Contrived cross-border arrangements that seek to generate debt deductions for non-assessable non-exempt income |
| This Taxpayer Alert describes certain cross-border financing arrangements which seek to generate debt deductions in Australia. These arrangements appear to be driven by the tax benefits that arise under section 25-90 of the Income Tax Assessment Act 1997. |
| TA 2008/7 - Application of Part IVA of the Income Tax Assessment Act 1936 to 'wash sale' arrangements |
| This Taxpayer Alert describes an arrangement called a 'wash sale' where an asset is disposed of, but there is no substantial change in economic interest in the asset. This may occur where the interest in the asset is in some way reinstated by the taxpayer, in order to apply a resulting capital loss or allowable deduction against a capital gain or assessable income already derived or expected to be derived. |
| TA 2009/8 - Exploitation of 1999 superannuation transitional provisions to obtain taxation and regulatory benefits |
| This Taxpayer Alert describes an arrangement that involves the transfer of benefits associated with the 1999 'transitional provisions' for self-managed superannuation funds (SMSFs) with pre-existing interests in unit trusts. |
| TA 2008/6 - Claiming tax deductions for debts from a previous tax planning scheme that are forgiven or where repayments are refunded |
| This Taxpayer Alert describes arrangements whereby taxpayers involved in a previous tax avoidance scheme enter into an arrangement under which they purport to be able to claim a tax deduction for debts relating to that scheme that have been forgiven or where repayments of the debt are refunded. |
| TA 2009/7 - Uncommercial contract manufacture arrangements to claim the wine equalisation tax (WET) producer rebate |
| This TPA describes uncommercial and collusive arrangements where one or more growers use a contract winemaker, so each such grower can attempt to claim the WET producer rebate by retaining title to their produce, until a pre-arranged sale to the winemaker. |
| TA 2008/5 - Certain borrowings by self managed superannuation funds |
| This Taxpayer Alert is concerned with arrangements under which the trustee of a self managed superannuation fund enters into certain limited-recourse borrowings, which may not meet the conditions in subsection 67(4A) and/or breach other provisions of the Superannuation Industry (Supervision) Act 1993, as well as related superannuation rules. |
| TA 2009/6 - Use of uncommercial indirect marketing arrangements to reduce wine equalisation tax (WET) |
| This TPA describes uncommercial and collusive arrangements that seek to reduce WET liability by using an interposed entity and an agency relationship to shift the point where WET liability is determined and to manipulate which methodology is used. |
| TA 2008/4 - Self-managed superannuation funds deriving income from certain uncommercial trusts |
| This Taxpayer Alert describes a non-arm's length arrangement under which a self-managed superannuation fund (SMSF) derives income through a direct or indirect interest in a closely-held trust. This Alert should be read in conjunction with Taxpayer Alert TA 2008/3. |
| TA 2009/5 - Use of an associate to obtain Goods and Services Tax ('GST') benefits on construction of residential premises for lease |
| This Taxpayer Alert describes an arrangement where an entity uses an associate in an attempt to secure input tax credits on the construction of residential premises for lease and defer the corresponding GST liability, in some cases indefinitely. |
| TA 2008/3 - Uncommercial use of certain trusts |
| This Taxpayer Alert describes a non-arm's length arrangement under which a taxpayer uses borrowed funds to acquire an interest, such as units, in a certain type of trust, which uses the funds to purchase income-producing property. |
| TA 2009/4 - Land owner's use of a registered associate to maximise input tax credit entitlements and reduce Goods and Services Tax (GST) payable under the margin scheme. |
| This Taxpayer Alert describes an arrangement that purportedly allows a land owner to register for GST as late as possible to minimise its GST payable, but still claim a full input tax credit on its acquisition of construction services from its associate. |
| TA 2008/2 - Use of certain legal structures established in Liechtenstein to attempt to avoid or evade Australian tax obligations |
| This Taxpayer Alert describes arrangements that attempt to utilise Liechtenstein legal structures to avoid or evade Australian tax. |
| TA 2009/3 - Bringing forward deductions to rehabilitate a mine site |
| This Taxpayer Alert describes an arrangement where an entity attempts to bring forward an income tax deduction for a future obligation to rehabilitate a mine site. |
| TA 2008/1 - Certain stapled securities involving notes and preference shares |
| This Taxpayer Alert describes those Stapled Security arrangements where a Note stapled to a Preference Share is issued by banks and other public companies. |
| TA 2009/2 - Certain cross-border Prepaid Forward Purchase Agreements |
| This Taxpayer Alert describes an arrangement using a Prepaid Forward Purchase Agreement which attempts to reduce the assessable income of an Australian resident taxpayer. |
| TA 2009/1 - Superannuation Illegal Early Release Arrangements |
| This Taxpayer Alert describes arrangements incorrectly offering people early release of their preserved superannuation benefits prior to retirement without meeting statutory conditions for such release. |
| TA 2012/7 - Self managed superannuation funds arrangements to acquire property which contravene superannuation law |
| The purpose of this Taxpayer Alert is to warn SMSF trustees and advisors to exercise care; ensuring any arrangements entered into by an SMSF to invest in property are properly implemented, particularly those involving limited recourse borrowing arrangements or the use of a related unit trust. |
| TA 2012/6 - Deduction generation from purported purchase of offshore 'emission units' that do not exist at the time of the arrangement |
| This Taxpayer Alert describes an arrangement where participants contract with an offshore entity to purportedly purchase offshore 'emission units' which may not exist. Participants pay a small upfront fee but deduct the entire purchase price in the year they enter the arrangement. |
| TA 2012/5 - Acquisition of intangible right for inflated consideration which is financed by supplier |
| This Taxpayer Alert describes an arrangement where an entity claims an input tax credit on a purported acquisition (on non-commercial terms) of an intangible right from a GST-registered supplier, with the provision of vendor finance under which payments are contingent on a future event. |
| TA 2012/4 - Accessing private company profits through a dividend access share arrangement attempting to circumvent taxation laws |
| This Taxpayer Alert describes arrangements where the accumulated profits of a private company are distributed in a substantially tax-free form to an entity associated with the ordinary shareholders of the private company. |
| TA 2012/3 - Structured financial products that exploit franking credits and other tax benefits |
| This Taxpayer Alert describes certain complex highly structured investment products that seek, amongst other things, to transfer franking credits. |
| TA 2012/2 - New Zealand Foreign Trust arrangements |
| This Taxpayer Alert describes arrangements where a New Zealand based foreign discretionary trust (New Zealand Foreign Trust) is used to avoid taxation on Australian sourced income. |
| TA 2012/1 - Non disclosure of foreign source income by Australian tax residents |
| This Taxpayer Alert describes arrangements under which Australian resident taxpayers who have derived income or other taxable amounts from foreign sources do not correctly include these amounts in their assessable income for Australian tax purposes. |
| TA 2011/5 - FBT Avoidance through an arrangement where an employer repays an employee's loan from a purported employee share trust |
| This Taxpayer Alert describes an arrangement where the employer uses salary sacrificed by employees to repay an employee's loan without regard to Fringe Benefits Tax. |
| TA 2011/4 - Deductibility of Unpaid Directors Fees |
| This Taxpayer Alert describes an arrangement where a company claims a deduction for directors fees notwithstanding that there is no payment to the directors of these fees in the current income year and/or subsequent income year(s). |
| TA 2011/3 - Arrangements involving holiday travel claimed as a work related, investment or self-education expense |
| This Taxpayer Alert describes arrangements where a taxpayer claims a deduction for expenses incurred in relation to various educational courses and seminars where the expenses have insufficient connection with the taxpayer's current income-earning activities and are private or domestic in nature. |
| TA 2011/2 - Certain labour hire arrangements utilising a discretionary trust to split income |
| Describes an arrangement where a labour hire firm makes a discretionary trust structure available for the use of individual taxpayers for the purpose of alienating income from personal services and splitting it between the individual taxpayers who perform the services and their associates. |
| TA 2011/1 - Loans to members of companies limited by guarantee and the operation of Division 7A |
| This Taxpayer Alert describes an arrangement where a company limited by guarantee (LBG company) is established to receive trust distributions. |
| TA 2010/8 - Gift deductions for donation of pharmaceuticals to charities operating overseas |
| This Taxpayer Alert describes a leveraged donation arrangement where a taxpayer (donor) claims a gift deduction for pharmaceuticals and other items to a Deductible Gift Recipient (charity) for use overseas, which far exceeds the amount of cash outlaid. |
| TA 2010/7 - GST - Retirement Village operators who on-sell services to residents in an attempt to claim greater input tax credits |
| This Taxpayer Alert describes an arrangement in which a retirement village operator ('RVO') increases its claims for input tax credits (or for decreasing adjustments) by assuming the role of a service supplier, such as an electricity retailer. |
| TA 2010/5 - The use of an unrelated trust to circumvent superannuation lending restrictions |
| This Taxpayer Alert describes an arrangement where a self-managed superannuation fund (SMSF) invests funds in an unrelated trust. The trust on lends the funds to a SMSF member/relative in an attempt to circumvent superannuation lending restrictions. |
| TA 2010/6 - The use of an unrelated trust to access funds of a private company in an attempt to circumvent Division 7A |
| This Taxpayer Alert describes an arrangement where a private company invests funds in an unrelated trust. The trust then on lends the funds to the private company shareholder, or an associate of a shareholder, in an attempt to circumvent Division 7A. |
| TA 2010/4 - Australian resident entities using promoted tax schemes in Samoa to claim purported deductions and conceal income or assets |
| This Taxpayer Alert describes an arrangement where Australian resident entities using promoted tax schemes in Samoa and/or other low tax jurisdictions to claim purported deductions and conceal income or assets. |
| TA 2001/01 - Home Loan Unit Trust Arrangement |
| This Alert describes an arrangement where taxpayers use a unit trust to acquire a property for residential use in order to access tax deductions generally available to investment properties. Simply it is about seeking deductions for private expenditure. |