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Beware 47A!

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Published on 01 Apr 07 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Section 47A is an anti-avoidance provision that deems certain benefits provided by Controlled Foreign Companies to other entities to be dividends. The ATO has recently released Draft Taxation Determination TD 2007/D1 which outlines the application of section 47A to situations where a CFC provides these covered benefits to another associated CFC. This article analyses the ATO’s reasoning and conclusions in the Draft Determination.

Author profile

Dr Philip Bender ATI
Dr Philip Bender, ATI is a barrister at the Victorian Bar. He is the author of Bender’s Australian Stamp Duties, published by the Tax Institute. He acts in Federal and State taxation, superannuation, and trusts and estates matters for taxpayers and revenue authorities. In the trusts area, he has acted in many taxation disputes involving trusts issues, and has acted in many trusts matters involving, amongst other topics, trust deed and will interpretation, alleged breaches of trust; trustee removal applications; judicial advice; charitable trusts; and superannuation death benefits disputes. - Current at 06 March 2023
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