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

TR 2022/D1Income Tax: s100A reimbursement schemes released by the ATO

A closer look at the *TR 2022/D1 - Income Tax: s100A reimbursement schemes* released today by the ATO which provides the Commissioner's view about these arrangements and the four basic requirements for section 100A to apply, namely the: 🔹 'Connection requirement' 🔹 'Benefit to another requirement' 🔹 'Tax reduction purpose requirement' 🔹 'Ordinary dealing exception' For example, scenarios that illustrate the principles in the Ruling, refer to: 1 - trust established under a will - Pg.107 2 - distribution to spouses with mixed finances - Pg.110 3 - gift from parents to a child - Pg.114 4 - trust entitlement gifted to trustee - Pg.116 5 - unpaid entitlements held on separate trusts - Pg.121 6 - non-commercial loan between family members - Pg.124 7 - dealing at arm's length and loan on commercial terms - P.128 8 - share buy-back arrangement - P.133 9 - circular flow of funds - P.148 NOTE: - The compliance approach is set out in PCG 2022/D1. - Information current as at 23 Feb 2022. - The decision of the Federal Court in Guardian AIT Pty Ltd ATF Australian Investment Trust v Commissioner of Taxation [2021] FCA 1619 (Guardian), referred to in this Ruling, is presently the subject of an appeal. - Examples contained in TR 2022/D1 are not binding on the Commissioner.

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