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Guardian case - tax appeal decision on section 100A – Trusts 

10/02/2023

On 24 January 2023, the Full Court of the Federal Court of Australia handed down its appeal decision in Commissioner of Taxation v Guardian AIT Pty Ltd ATF Australian Investment Trust [2023] FCAFC 3. The Court upheld the original judgement in favour of the taxpayer in relation to the application of section 100A but allowed the […]

ATO position on section 100A for trusts finalised

20/12/2022

On 8 December 2022, the Australian Taxation Office (ATO) published its final views regarding the application of section 100A of the Income Tax Assessment Act 1936 (ITAA 1936) for trusts. SW reviews the changes from the draft ruling and additional guidance from the Commissioner. The ATO’s final interpretation of the law, and their compliance approach […]

Guardian case - section 100A win for the taxpayer

23/02/2022

In December 2021, the Federal Court handed down its decision in Guardian AIT Pty Ltd ATF Australian Investment Trust v Commissioner of Taxation [2021] FCA 1619. The court found in favour of the taxpayer in relation to the application of section 100A. There is little guidance around the application of section 100A particularly in respect […]

Ian Kearney

23/11/2021

I have more than 30 years of experience providing strategic tax advice and compliance solutions. I primarily advise large, complex private groups and ASX-listed entities, and I am recognised as a leading expert in the taxation of trusts. I have served on the Australian Taxation Office’s National Tax Liaison Group and National Tax Liaison Group […]

Abi Chellapen, Partner

23/11/2021

I have more than 15 years’ experience providing strategic advice across all areas of tax law. I combine strong technical and practical skills to advise and assist clients across a range of industries, with a particular focus on funds management and property. My clients include ASX-listed and wholesale property funds, equity funds, corporate entities, and […]

CTS Country-by-Country Reporting

05/03/2018

Streamline and automate the entire tax reporting and compliance process. FIND OUT HOW! Call us for a FREE demo on 03 8635 1800. Complete Tax Solutions (CTS) is an intelligent and automated tax solution that improves accuracy and delivers increased efficiency to a diverse range of businesses and industries. The CTS suite of products enable […]