In Mills v Commissioner of Taxation, the Australian Federal Court decided that securities issued by the Commonwealth Bank of Australia had the purpose of enabling holders of the securities to obtain an imputation benefit.
Australia has moved one step closer to reforming resource taxes with the government’s acceptance of the Policy Transition Group’s (PTG) 98 recommendations.
The Federal Court of Australia has upheld in part the deductibility of a dividend paid on a redeemable preference share (RPS) in the case of Noza Holdings Pty Ltd v Commissioner of Taxation.
Advisers have said the reason behind the delay for transfer pricing rules in Russia is because of unresolved issues about substance, including the mechanism for correlative adjustments and the provisions dealing with the period in which the tax authorities can conduct transfer pricing audits.
