Source: The Tax Specialist Journal Article
Published Date: 1 Apr 2023
As the first diverted profits tax (DPT) case hits our courts, a degree of "mystery" continues to surround this anti-avoidance rule and its sister rule, the multinational anti-avoidance law (MAAL). Both rules are key tools in the ATO's anti-avoidance arsenal, yet uncertainty remains as to when the ATO will seek to apply the rules and how organisations can engage with the ATO to avoid disputes in this arena. This article examines circumstances where the ATO is considering the DPT and MAAL, and how organisations can prepare if the ATO advises that the rules are potentially in scope.
More by Elizabeth Colbran
Sorry, this is subscriber only content.
To gain access to this material and much more - Subscribe Now.
(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).
Already a Subscriber? Login now
Already a Subscriber? Login now
Details
The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The Tax Institute
(ABN 45 008 392 372 (PRV14016))
("TTI")
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.
Tags