The Federal Court in Morton v FCT [2025] FCA 366 (click here) allowed a taxpayer’s appeal against assessments that sought to tax on revenue account the gains made from the subdivision and sale of a family farm. Shortly after the farmland was zoned residential, the taxpayer engaged an external developer to undertake a project which […]
As we approach the end of the financial year, and it’s time to get your year-end tax planning sorted. We’re here to help you get everything in order. Watch our Pitcher Partners’ year-end tax planning webinar, where Tax Advisory Partner Daniel Burt, will guide you through all the essential aspects of income tax planning. During […]
With 15 May now behind us, attention turns to 30 June. With the ATO increasing its compliance focus at all levels (firms, funds, investors) and trusts in particular continuing to be under the microscope, responsible entities, trustees and fund managers must prioritise tax compliance and investor reporting. Failing to address key issues could lead to […]
As the end of the financial year approaches, it is time to start thinking about whether your year-end tax planning is in order. Tax planning requires not only a consideration of income and deductions for the year but also looking forward to opportunities ahead of 1 July. In this article we identify the key tax […]
Key points While still subject to legislative passage it is looking increasingly likely that the Government still intends to introduce the new tax. It will mean that income, such as interest, derived on super balances above $3m will be taxed at broadly 30% (15% fund tax rate and 15% new tax rate) Individuals with large […]
In her first term as Victorian Treasurer, Jaclyn Symes has handed down a Budget which provides targeted cost of living relief, but fails to address the increasing costs of doing business in Victoria or provide any relief from the significant tax burden that is now borne by residents – particularly property owners, investors and developers. […]
This article was updated on 20 May, 2025. As we await the outcome of the ATO’s application for special leave to appeal to the High Court in Bendel, some taxpayers may have taken the position of putting their unpaid present entitlements (“UPEs”) on complying loan terms without explicitly converting them to a loan. An article […]
Legislation making the General Interest Charge (“GIC”) and Shortfall Interest Charge (“SIC”) non-deductible from 1 July 2025 has now passed both houses of Parliament and is set to impact taxpayers with tax liabilities that are overdue or arise due to tax shortfalls. Taxpayers should carefully consider the effects of the new measure. In particular, taxpayers […]
Pitcher Partners has made a submission to the ATO to Draft Taxation Determination TD 2025/D2. The Draft TD relates to the application of section 109R in Division 7A where the ATO provide their view that section 109R can apply to disregard a repayment of a Division 7A loan where the borrower obtains a new loan […]
The ATO has now formalised its views on repayments of Division 7A loans where new loans are subsequently made indirectly via other entities. A specific anti–avoidance provision in Division 7A disregards repayments of loans in circumstances where the borrower obtains a new loan from the same company. As a result, the original loan remains unpaid […]
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