Stapled Structures for Infrastructure – whether Part IVA ‘tax avoidance’ provisions could apply – as the Commissioner postulates in Tax Alert TA 2017/1 (unlikely)
A paper prepared for the Tax Institute’s National Infrastructure Conference, by Mr Greg Davies QC and Mr Eugene Wheelahan of the Victorian Bar – on 17 May 2018. 1 Introduction In its Taxpayer Alert, TA 2017/1, the Australian Taxation Office (ATO) states that it is reviewing arrangements which “attempt to fragment integrated trading businesses…