This paper covers the following topics:
- types, treatment and the ATO's views on resident contracts
- treatment of deferred management fees
- capital versus revenue distinction and the importance of the characterisation
- transitional issues arising from ATO Taxation Ruling 2002/14 compared to Taxation Ruling TR94/24
- the practical impacts and difficulties of tax consolidation in the industry
- taxation implications arising from IFRS and the proposed Taxation of Financial Arrangements Bill applying to the industry.