The Australian Taxation Office (ATO) has finalized Taxation Determination (TD) 2023/5, Income tax: aggregated turnover and connected entities - Commissioner's discretion that an entity does not 'control' another entity. TD 2023/5 addresses specific issues that arise when the ATO considers whether to exercise the Commissioner's discretion to determine that one entity doesn't control another entity, which is central to determining whether entities are connected. The Commissioner has the discre…