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Recent Developments

15 April 2014
Tony Frost (Managing Director, Greenwoods & Freehills) and Cameron Hanson (Partner, Herbert Smith Freehills) contributed the chapter on Australia to the second edition of The Tax Disputes and Litigation Review, published in February 2014.
14 April 2014
Greenwoods & Freehills is pleased to announce that 15 of our Directors and two of our Special Counsel have been named to the 2014 Edition of Best Lawyers.
11 April 2014
A summary of selected tax developments for the week ending 11 April 2014
8 April 2014
The Board of Taxation has released a Discussion Paper as part of the review of the debt / equity rules commissioned by the previous government. This Tax Brief outlines the principal areas of focus of the Paper and the main issues it puts on the table for review.
4 April 2014
A summary of selected tax developments for the week ending 4 April 2014
28 March 2014
A summary of selected tax developments for the week ending 28 March 2014
24 March 2014
Another piece of the ‘base erosion’ puzzle has appeared with the release of the OECD’s recommendations for addressing cross-border hybrids. This Tax Brief analyses the 2 OECD Public Discussion Drafts on ‘neutralising the effects of hybrid mismatch arrangements’ and their implications, both for Australia’s future treaty practice and for some common cross-border structures and instruments. If these recommendations are pursued, Australia’s tax law could become much more contingent, and structurally dependent on the policies and practices of other governments.
21 March 2014
A summary of selected tax developments for the week ending 21 March 2014
14 March 2014
A summary of selected tax developments for the week ending 14 March 2014
12 March 2014

There is precious little to indicate the current state of curial or administrative play on Part IVA: despite a barrage of articles, there is no recent case law or Australian Taxation Office (ATO) rulings/practice statements on point.

However, there is one notable development: the ATO released the minutes of a 18 July 2013 National Tax Liaison Group (NTLG) consultative workshop on Part IVA. The Minutes contain important insights into the current ATO thinking on Part IVA – and that thinking can reasonably be expected to be reflected in the impending update to the Part IVA practice statement (PS LA 2005/24).