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Taxation of Financial Arrangements - Practical Application

Published on 09 Mar 2006 | Took place at Rialto Hotel on Collins, Melbourne, VIC

The release of the draft Taxation of Financial Arrangements legislation provides an opportunity to review the impact of this radically different approach to tax recognition of financial arrangements. These materials address the scope and the timing rules involved, focus on the practical application of the proposals, their shortcomings, benefits and financial impacts.

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Individual sessions

Taxation of Financial Arrangements - timing rules

Author(s):  Neil WARD

This workshop paper covers the following topics:

  • compounding accruals - potential impacts of this fundamental default rule
  • realisation - what will still be on a cash/realisation basis?
  • fair value - who will elect and to what extent?
  • retranslation - the rules / interaction with the Forex Rules
  • hedging - the perceived benefits of electing into hedging.

This paper was also presented at the 'Taxation of Financial Arrangements' seminars held in Melbourne on 9 March 2006 and Sydney on 22 March 2006.

Materials from this session:

Taxation of Financial Arrangements - scope and exceptions

Author(s):  Tony FROST

This workshop paper covers:

  • is the very wide definition of a 'financial agreement' workable?
  • are the exceptions and carve-outs adequate?
  • alternative approaches?
  • comparison to the financial accounting definition of a 'financial instrument'
  • the New Zealand experience
  • character rules: is the deemed revenue treatment appropriate?

This paper was also presented at the 'Taxation of Financial Arrangements' seminars held in Melbourne on 9 March 2006 and Sydney on 22 March 2006.

Materials from this session: