Advice under development – trust specific issues

We are developing advice and guidance on the following trust issue.

On this page

• [4099] 100A reimbursement agreements [new]

[4099] Section 100A reimbursement agreements

Title

Update to Taxation Ruling TR 2022/4 Income tax: section 100A reimbursement agreements

Purpose

TR 2022/4 will be updated to reflect two recent Full Federal Court decisions, namely Commissioner of Taxation v Guardian AIT Pty Ltd ATF Australian Investment Trust [2023] FCAFC 3 and Bblood Enterprises Pty Ltd v Commissioner of Taxation [2023] FCAFC 89.

Expected completion

September 2023

Title

Update to Practical Compliance Guideline PCG 2022/2 Section 100A reimbursement agreements – ATO compliance approach

Purpose

A minor update will also be made to this Guideline to further clarify some features of green zone arrangements.

Expected completion

September 2023

Contact

Justin Dearness

Phone: 07 3213 5745

Justin.Dearness@ato.gov.au

We are developing advice and guidance on the following trust specific issues.