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Taxation of Financial Arrangements


Thursday, 5 August 2004

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The purpose of this paper is to provide further guidance to taxpayers and their advisers on measures concerning the implementation of the Taxation of Financial Arrangements reforms. However, to the extent that the announced measures require a change in the law the information in this paper is provided merely as a guide as to how the measures might operate. The measures announced by the Minister for Revenue and the Assistant Treasurer concern:

A. amendments to the foreign currency provisions ;

These amendments fall into 3 broad categories:
1. amendments constituting a policy change;
2. technical amendments; and
3. minor technical amendments.

B. regulations made under regulation making powers in the foreign currency provisions;

C. technical amendments to the debt/equity and capital gains tax (CGT) provisions; and

D. deferral of the commencement of the remaining stages of the TOFA reforms.

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