One Page: Taxpayer Alert 2020/2

James Macky discusses the ATO’s review of cross-border arrangements that mischaracterise a structure used by foreign investors.

The Australian Taxation Office (ATO) released Taxpayer Alert 2020/2 on 25 May 2020, highlighting cross border arrangements connected with foreign investment into Australian entities that the ATO sees as providing tax outcomes that are inconsistent with commercial features of the investment.The ATO says the arrangements are usually not “vanilla debt and equity investments”.Typically the arrangements display one or more of the following features:the Australian resident has struggled to obtain c...

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Authors: James Macky

Published Date: 05 June 2020