ATO raises the evidence bar for treaty claims through fiscally transparent entities
Client alertATO guidance increases evidence requirements for treaty claims through FTE structures.
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By: Michael Catterall, Yan Wong, Daniel Kave, Avinesh Naidu, Brett Curtis
17 Apr 2023 2 min read
Grant Thornton previously discussed the ED in summary and identified a number of areas of interest and concern.
We have made submissions to Government which reflect our analysis and we believe include the views of our affected clients, and their bankers and lawyers.
In essence, our submissions aim to reasonably improve the ability of taxpayers to comply with the new rules whilst respecting the Government’s underlying policy intent. They also reflect common concerns across industry and we anticipate that a number of taxpayers and industry or professional bodies will have a similar view as to the impact of the proposed changes.
We trust that the Government will give due consideration to the weight of public opinion in areas of common concern, and we welcome any consultation that is undertaken.
Please contact us if you wish to discuss our submissions or would like further detail about the exposure draft.
ATO guidance increases evidence requirements for treaty claims through FTE structures.
On 16 March 2023 the Federal Government released its Exposure Draft (ED) legislation, which was first announced as part of its October 2022 Federal Budget Thin Capitalisation measures.
On 16 March 2023 the Federal Government released its Exposure Draft (ED) legislation giving effect to its October 2022 Federal Budget thin capitalisation measures, which will apply mainly to multinationals with high interest deductions for income years commencing on or after 1 July 2023.