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The capital v revenue distinction for labour costs paper

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Published on 04 Mar 10 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • a commentary on the legal analysis in the ATO's discussion paper
  • a view about the extent to which the discussion paper represents a change in the ATO's position
  • some thoughts about how to resolve any disputes that might arise from the application of the ATO's views on this.

Author profile

Frank Drenth
Frank has been Executive Director of the Corporate Tax Association (CTA) since 1998. Frank has had involvement on behalf of external stakeholders in the development of Australia's tax policy and law, and aspects of tax administration relevant to large companies. Frank is a member of a number of consultation groups, including the NTLG, the Large Business Advisory Group, and various specific issue consultation groups. In 2012 Frank was a member of the Business Tax Working Group, which looked at the tax treatment of losses as well as at the business tax system more broadly. More recently, he was appointed to the Stakeholder Reference Group on the Taxation of Multinational Enterprises in Australia. Frank has also contributed to the development of Australia's General Anti-Avoidance Rules through his membership of the Part IVA Roundtable. - Current at 14 August 2013
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