The Full Federal Court has handed down its decision in FCT v Guardian AIT Pty Ltd [2023] FCAFC 3 (“Guardian”) which considered the application of anti-avoidance rules to trust distributions to a corporate beneficiary.
The ATO has finalised draft guidance on the application of section 100A to trust entitlements, staying close to the original released earlier this year. The finalisation comes despite two cases (both for and against the Commissioner) currently on appeal to the Full Federal Court. The guidance provides a very stringent view by the ATO on what may fall within the scope of section 100A. This may create significant risks with respect to trust distributions that will need to be managed very carefully.
Irina specialises in state taxes, including duty and land tax. Throughout her career, she has provided comprehensive and practical multi-jurisdictional advice on the consequences and opportunities across several sectors in relation to a broad range of matters. These matters include business and asset acquisitions, corporate group restructures, strategic structuring of transactions and projects to achieve […]
As a chartered accountant with over 10 years of experience in public practice, Ben is a well-rounded professional with diverse industry experience with particular expertise advising on taxation issues affecting corporate and multinational clients with an emphasis on the resources industry. With an impressive breadth of international experience under his belt, Ben has advised outbound […]
Earlier this year, the ATO released long-awaited guidance on the application of section 100A. Find out more.
Four years after suspending their guidelines relating to the allocation of profits of professional firms, the Australian Taxation Office (“ATO”) released PCG 2021/4 (“Guidelines”) setting out its revised compliance approach.
Elizabeth offers tax advisory services to a range of clients including those in the information, communications and entertainment industries, manufacturing and industrial markets, mining industry and funds management sector. Over the life of her career Elizabeth has solved complex tax issues, with her main focus always on gaining the best results for her clients. Elizabeth […]
Lawrence is a Client Director for Tax Advisory and has provided tax specialist advisory for over 20 years. With a client base consisting of predominantly business owners, his specialities include tax treatment and implications for commercial transactions, effective tax structuring, the preparation of businesses for sale or purchase and mergers or demerger matters. Additionally, Lawrence […]
Joining Pitcher Partners in 2007, Yina has worked with clients across a range of industries, including logistics, property, and financial services, to name a few. She became a partner of the Melbourne firm in 2021. Yina offers strong technical expertise in and knowledge of income tax in Australia.Yina’s clients value her ability to make her […]
Scott is a proven leader and a trusted advisor. His breadth of experience spans taxation advice and assistance, financial analysis, business valuation advice, management reporting, budgeting and cashflow management. Scott has a special interest in helping business leaders identify real opportunities by understanding their unique story, appreciating their vision, challenging their thinking and building a […]
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