29 April 2013
In this week's Tax highlights we feature:
- Parent company’s market support payments not deductible: The ATO has released a draft tax determination expressing the preliminary view that support payments made by a parent company to a subsidiary are capital in nature and not deductible – instead, they form part of the cost base of the parent company’s shares in the subsidiary
- Cayman Islands LP not liable to tax on gain on sale of mining shares: The Federal Court has held that the Australia/United States double tax agreement authorised Australia to tax (according to its domestic law) US resident limited partners on their share of a gain derived on the sale of shares by a limited partnership, not the limited partnership itself
- Proposed Part IVA amendments: The ATO has advised taxpayers of its administrative treatment of arrangements which have been entered into between the date of application of the proposed amendments to the general anti-avoidance provisions and the date on which the measures become law.
Plus we provide our synopsis of the latest legislative developments, cases, announcements, and ATO information and releases.