Finance Investment TOFA

TOFA - A new world of economic substance?

Source: QLD

Published Date: 13 Feb 2013

 

At its essence, TOFA attempts to systematically align the tax treatment of financial arrangements towards their economic substance rather than their legal form.

This presentation examines:

  • how do the economic substance provisions work in practice?
  • when does the economic substance approach not apply in practice, i.e. what might be the limits of this economic substance approach?

Issues considered include:

  • economic substance under accounting principles
  • interactions with other parts of the Act that impose non-economic substance-based approaches
  • impact of tax character on substance-based analyses
  • deliberate design features in Div 230 that move away from economic substance
  • consideration of the synthetic disposal and non-disposal rules.

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Individual Session

TOFA - A new world of economic substance?

Author(s): Phillip Cole

Details

  • Published By: Phillip Cole
  • Published On:13 Feb 2013
  • Took place at:Hyatt Regency Sanctuary Cove, Gold Coast

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