MWYS and CofT – Profits within a ‘dual listed’ structure, were only CFC attributable, on purchases from the Australian side of the structure because the dual-listed companies were not CFC ‘associates’

The AAT has decided that only part (not all) of the profits, of a Swiss company, should have been attributed to the Taxpayer, under the CFC provisions (as “tainted sales income”), despite Swiss Co being 100% (indirectly) owned by the Taxpayer and a UK company, under a dual-listing arrangement. Though this is a decision of…

Capital Gains Tax (CGT) withholding regime – ATO updates its webpage on ‘clearance certificates’ for trustees

The information on the ATO website, on Capital gains withholding clearance certificate application online form and instructions – for Australian residents, has been updated by the ATO. It notes that, if a corporate trustee does not have a TFN, an attachment can be included to provide the details of the relevant trust. The updated page, on…