Show download pdf controls
  • Taxpayer Alert 2020/05

    We recently published a Taxpayer Alert regarding structured arrangements that provide imputation benefits on shares acquired where economic exposure is offset through use of derivative instruments.

    TA 2020/5 confirms our concerns over these arrangements. We are especially concerned that some arrangements may involve taxpayers inappropriately receiving the benefits of franking credits whilst attempting to avoid the substantive rules designed to maintain the integrity of the imputation system.

    We are reviewing arrangements that are intended to provide imputation benefits to Australian taxpayers in respect of a parcel of shares where, as a result of derivative instruments entered into as part of the arrangement, the taxpayer retains no or nominal economic exposure to the dividend and capital performance associated with that parcel of shares.

    If you have entered, or are contemplating entering, into an arrangement of this type:

    Last modified: 11 Dec 2020QC 64408