The Australian Taxation Office (ATO) issued Draft Taxation Ruling TR 200/D8 dealing with transfers of property or services to a non-resident company owned by a non-resident trustee aimed to circumvent the anti-deferral rules.
The Draft Ruling expresses the ATO's view that as a result of the transfers, the resident may, for tax purposes, be required to include the whole assessable income of the non-resident trust in its assessable income under the anti-…