Publication
Essential Corporate News: Week ending 24 May 2024
On 21 May 2024 the Financial Conduct Authority (FCA) published Primary Market Bulletin 49 (PMB 49) covering a range of topics covering a range of areas including those summarised below.
Global | Publication | February 2017
The Australian Taxation Office (ATO) released a controversial Taxpayer Alert, TA 2017/1 on 31 January 2017. The Taxpayer Alert relates to structures involving both a company (taxed at the corporate rate) and a trust (taxed as a flow through vehicle). The ATO has particularly highlighted structures involving a managed investment trust (MIT) with overseas investors.
The Taxpayer Alert is likely to affect investors in numerous asset classes, including infrastructure and renewables.
Investors need to carefully consider whether their investments are likely to fall within the (very broad) parameters identified by the ATO and should develop a strategy for engaging with the ATO.
Which structures are the ATO concerned about?
The ATO is concerned about “rental staples” (and similar structures where the entities are not stapled). This structure involves the following:
Further, the ATO has also identified these structures as being of concern:
How will the ATO challenge them?
The ATO may challenge the structures under one or more of the following methods:
Which structures should still be OK?
Further information
For information about the implications of this development for your business, please contact one of our Australian Tax partners (see below).
Publication
On 21 May 2024 the Financial Conduct Authority (FCA) published Primary Market Bulletin 49 (PMB 49) covering a range of topics covering a range of areas including those summarised below.
Publication
As the world enters the age of artificial intelligence, the use of technology in the legal sector continues to create interpretative difficulties and misunderstandings, sometimes with serious consequences, over seemingly trivial matters.
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