This expert panel shared their views on the Full Federal Court decision in Commissioner of Taxation v Guardian AIT Pty Ltd ATF Australian Investment Trust [2023] FCAFC 3 and the recently finalised ATO guidance released on 8 December comprising:
- TR 2022/4 Income tax: s100A reimbursement agreements; and
- PCG 2022/2 s100A reimbursement agreements – ATO compliance approach.