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brisbane • sydney • melbourne


A collection of updates, articles and papers written by The Little CFO & The Little CFO Legal

TA 2021/2 Disguising undeclared foreign income as gifts or loans from related overseas entities

The ATO has released a new Taxpayer Alert in relation to situations concerning the disguising of undeclared foreign income as gifts or loans from related overseas entities.

The ATO are currently undertaking reviews and audits and are actively engaging with taxpayers who have entered into these arrangements.

Taxpayers and their advisers who enter into these arrangements will face substantial penalties and may be at risk of potential sanctions under criminal law.

As part of the review and audit process, the ATO uses data:

🌍 obtained from foreign countries

🌍 obtained from AUSTRAC

🌍 obtained via the Common Reporting Standard; and

🌍 obtained via the Foreign Account Tax Compliance Act. In our upcoming series of Taxpayer Alert posts, we will set out the examples of arrangements from the ATO's Taxpayer Alert where foreign assessable income is disguised as a gift or loan from a related overseas entity.

⚠️ If you have received a notice from the ATO regarding your tax affairs or have concerns about potential mistakes in your tax reporting, contact us for a confidential consultation:


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Should you require advice please connect with us so that we may provide advice tailored to suit your specific circumstances.

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