The ATO has been issuing Surveys of Partnership and Service Trust Arrangements. Recipients of the Survey are required to respond within 28 days of receiving the Survey.
The survey's covering letter notes that the ATO 'has concerns about the commerciality of the arrangements including the fees paid...the way the cost base has been calculated and whether all costs have been fully recognised and the possible application of Part IVA'.
The survey seeks information on, among other things:
- the service provided to the partnership
- the structuring of the fee arrangements
- the commercial advantage to the partnership of acquiring the services from the service entity rather that an unrelated third party.
Before completing the survey you need to understand the types of arrangements the ATO will be seeking to identify and the action that it might take.