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Imported hybrid mismatches: ATO PCG

Australia - April 27 2021 The hybrid mismatch rules, introduced in 2018, are some of the most complex rules for taxpayers to apply. Very broadly, they typically apply where…

Andrew Hirst, Julian Pinson.

Paying out employee entitlements: a “black hole” deduction (for now)?

Australia - March 2 2021 The judgment in Clough Limited v Commissioner of Taxation [2021] FCA 108 rules out claiming a deduction under ordinary principles for payments to…

Edward Moore, Toby Eggleston.

Wind farm assets: chattels or fixtures? The Ararat Wind Farm case.

Australia - January 27 2021 A recent test case in the Supreme Court of Victoria in AWF Prop Co 2 Pty Ltd v Ararat Rural City Council [2020] VSC 853 confirms that the value of…

Andrew White, Edward Moore, Hugh Paynter, Leah Serafim.

ATO targets the use of derivatives by superannuation funds and fund managers

Australia - December 7 2020 The ATO’s focus on entitlement to franking credits where a taxpayer has partly hedged their interest in the underlying securities continues, with the…

Andrew White, Edward Moore, Julian Pinson.

The arm’s length value of an uneconomic asset - the VPN appeal

Australia - October 28 2020 The recent Full Federal Court decision in Victoria Power Networks partially overturned the first instance decision and clarifies that the arm’s…

Chris Colley, David Bond, Naison Seery.