This presentation looks at some practical emerging issues flowing from the operation of sections 45A and 45B in relation to distributions by companies including:
- overview of ss 45A and 45B including role, function and application so far
- S45B and demergers
- where is the ATO likely to apply the provisions?
- how do we speed up the process and add certainty to getting the Commissioner's favourable determination?
- how are these provisions to be practically applied by taxpayers - does it mean that every transaction involving a distribution by a company needs a ruling from the ATO before it can proceed?