Part IVA of the Income Tax Assessment Act 1936 (the general anti-avoidance rule) can be applied by the Commissioner only where a scheme has been entered into for what purpose?
Tax Theory Policy Anti Avoidance
Question · Medium
Which set of eight matters must the Commissioner consider when determining whether the dominant-purpose test in Part IVA is satisfied?
A 'tax benefit' for Part IVA purposes is identified by comparison with what hypothetical scenario?
Question · Hard
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The Multinational Anti-Avoidance Law (MAAL) and the Diverted Profits Tax (DPT) are best described as:
Which principle reflects a key objective of a good tax system as commonly evaluated in tax policy analysis?
Question · Easy
When a promoter markets an arrangement that the Commissioner considers a tax exploitation scheme, which regime may impose civil penalties on the promoter?
Which statement about the interaction between Part IVA and specific anti-avoidance provisions is correct?
A taxpayer seeks certainty about the tax treatment of a proposed transaction before lodging. Which ATO product provides binding guidance specific to their facts?
Under Part IVA, when the Commissioner makes a determination, the consequence is that the Commissioner:
Which of the following is a recognised function of Australia's transfer pricing rules in Subdivision 815?
Tax reform proposals are often assessed for their impact on 'vertical equity'. Vertical equity is best described as the principle that:
Which ATO publication typically warns taxpayers and advisers that the ATO has concerns about a particular emerging arrangement and is reviewing it?
The base erosion and profit shifting (BEPS) agenda primarily addresses:
A discretionary trust derives net income but the trustee makes no valid distribution and no beneficiary is presently entitled at year end. How is the net income generally taxed?
Trusts And Distributions
Under the proportionate approach in Division 6 of the ITAA 1936, a beneficiary's share of the trust's net (taxable) income is determined by reference to:
What is the effect of a valid family trust election (FTE) for a discretionary trust?
A trust makes a capital gain eligible for the CGT discount and streams it to a specifically entitled beneficiary. Under the streaming rules in Subdivision 115-C, the capital gain:
Section 100A of the ITAA 1936 (reimbursement agreements) is most likely to be a concern where:
Division 6AA applies to certain 'eligible' income distributed to a minor (under 18). The effect is generally that:
For a discretionary trust to distribute income for a year and have beneficiaries assessed, the trustee generally must make a valid distribution resolution by what date?
Where a trust has a tax loss (revenue loss), the trust loss provisions in Schedule 2F require it to satisfy certain tests to recoup the loss. A fixed trust must generally satisfy:
A beneficiary who is presently entitled to trust income but is under a legal disability (for example, a minor without their own tax affairs) is generally assessed how?
A unit trust that meets the requirements of a 'public unit trust' carrying on certain non-trading activities may be taxed as a company under which provisions?
A managed investment trust (MIT) that qualifies as an attribution MIT (AMIT) under Division 276 benefits from which key feature?
The concessional (15%) tax rate generally applies to the income of a complying superannuation fund in the accumulation phase. Investment earnings supporting a retirement phase income stream are generally:
Superannuation
For the 2024-25 year, the standard concessional contributions cap to a superannuation fund is:
Division 293 tax imposes an additional 15% tax on certain concessional contributions for individuals whose income for surcharge purposes plus concessional contributions exceeds:
A self-managed superannuation fund (SMSF) acquires a commercial property and leases it back to a related business. This is permitted only if:
Non-arm's length income (NALI) derived by a complying superannuation fund is taxed at what rate?
A superannuation death benefit paid as a lump sum to a non-tax dependant (for example, an independent adult child) is generally:
The transfer balance cap limits the total amount a member can transfer into the tax-free retirement phase. For 2024-25 the general transfer balance cap is:
A taxpayer aged 60 who sells an active business asset and qualifies for the small business 15-year exemption may contribute the exempt proceeds to superannuation using:
The Superannuation Guarantee (SG) rate that employers must contribute for eligible employees in the 2024-25 year is:
An SMSF that breaches the in-house asset rules at year end (in-house assets exceed 5% of total fund assets) must:
A limited recourse borrowing arrangement (LRBA) used by an SMSF requires that:
A base rate entity company with aggregated turnover under $50 million and no more than 80% base rate entity passive income is taxed at what corporate rate for 2024-25?
Companies And Distributions
A company has a corporate tax rate for imputation purposes of 25%. When it pays a fully franked dividend of $7,500, the franking credit attached is calculated as:
Division 7A treats certain loans, payments and forgiven debts by a private company to a shareholder or associate as:
The Division 7A benchmark interest rate that applies to complying loan agreements for the 2024-25 income year is:
A 'benchmark franking percentage' rule means that a company must frank all frankable distributions made within a franking period at:
An individual shareholder on a 47% marginal rate (including Medicare levy) receives a fully franked dividend of $7,000 with a $3,000 franking credit. What is the approximate net tax payable on the dividend after the franking credit offset?
When a company makes an off-market share buy-back, the amount debited to the share capital account is treated as a capital component, and the balance is generally treated as:
For a shareholder to be entitled to franking credits on a dividend, the holding period rule generally requires the shares to be held 'at risk' for:
Where a private company has paid a dividend but a Division 7A complying loan was instead the better outcome, the Commissioner may exercise discretion under which provision to disregard a deemed dividend in cases of honest mistake or inadvertent omission?
A company with a franking account in deficit at year end is liable to pay:
A company seeks to deduct prior year tax losses. It fails the continuity of ownership test (more than 50% ownership has changed). It may still deduct the losses if it satisfies:
A dividend paid out of a company's share capital account rather than profits is generally:
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