Division 7A and Sub-Trust Arrangements
Division 7A – Sub-trust Arrangements Draft Taxation Determination TD 2022/D1 The tax determination (“TD”) deals with trust distributions made to corporate beneficiaries that are not paid ie. UPEs. Trust distributions are commonly made to corporate beneficiaries in order to cap the tax rate on the distributions to the corporate tax rate. However, where the distribution […]
Long-awaited draft guidance on Section 100A
Tax avoidance via trust distributions – ATO guidance on s100A reimbursement agreements Draft Taxation Ruling TR 2022/D1 & Draft Practical Compliance Guideline PCG 2022/D1 S100A is an anti-avoidance provision within the tax legislation which targets trust distributions exhibiting the characteristics outlined below. It has not been widely used by the ATO to date but these […]
