Kseniia Gasiuk

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Minerva – Part IVA - Full Federal Court gives the taxpayer back its “Liberty”

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Minerva – Part IVA - Full Federal Court gives the taxpayer back its “Liberty”

In 2022, the decision of the Federal Court in Minerva Financial Group Pty Ltd v Commissioner of Taxation [2022] FCA 1092 raised the question that tax benefits emanating from trustee decisions could be subject Part IVA. At that time, we said we think ‘no’ (see here).  

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TR 2024/D1: Navigating the draft ruling TR 2024/D1 on software distribution arrangements

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TR 2024/D1: Navigating the draft ruling TR 2024/D1 on software distribution arrangements

On 17 January 2024, the Australian Taxation Office (ATO) issued a revised draft taxation ruling, TR 2024/D1, which addresses the taxation implications of payments relating to software distribution arrangements.

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When is a public company not a public company?

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When is a public company not a public company?

In the realm of tax law, the differences between the definitions of private and public company for tax purposes carries profound implications, particularly within the framework of Division 7A. Advisors must understand these nuances to guarantee compliance and adeptly manage their financial matters.