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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

Ian has over 30 years’ experience in providing strategic tax solutions. He primarily acts for large, complex private groups and ASX listed entities and is recognised as a leading expert on Division 7A and the taxation of trusts. Ian has served on the Australian Tax Office (ATO) National Tax Liaison Group and also on the […]

Abi Chellapen, Partner

23/11/2021

Abi has over 15 years’ experience in providing strategic tax advice in all areas of tax law. She has strong technical and practical skills advising and assisting clients across a range of industries, but with particular emphasis on funds management and property. Abi’s clients include a number of ASX listed and wholesale property funds, equity […]

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 […]