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TOFA for real property paper

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Published on 28 Jul 08 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

With the introduction of TLAB (TOFA) 2007, TOFA is closer becoming a reality for taxpayers. This paper looks at the impact of proposed Division 230 on common leasing and real property transactions. This paper covers:

  • the current state of TOFA legislation
  • a general overview of the provisions
  • a discussion of key property related exclusions
  • the likely outcomes for common leasing and property transactions
  • the interaction with existing tax law
  • unresolved issues requiring consultation and clarification.

Author profile

Joshua Cardwell CTA
Photo of author, Joshua CARDWELL Josh Cardwell has over 30 years’ transactional consulting and compliance experience with a specialised focus on the real estate sector. He has extensive experience across inbound, outbound and domestic real estate clients, including providing advice on fund establishment, property/entity acquisitions and disposals, financing and repatriation and stapled structures. Prior to joining KPMG, Josh was Head of Real Estate Tax – Australia at PwC Australia, the Head of Mergers & Acquisitions at Greenwoods & Freehills and a Tax Partner at Deloitte. Josh was named 2019 Corporate Tax Adviser of the Year by the Taxation Institute of Australia and is a long-standing member of the Property Council of Australia’s Capital Markets Income Tax Committee. - Current at 25 August 2026
Click here to expand/collapse more articles by Joshua CARDWELL.

 

This was presented at Annual Tax Forum .

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