OrbitaxThe Australian Taxation Office (ATO) released for comment Draft Taxation Determination ATO TD 2008/D15, which considers the Australian (and UK) taxation consequences of paying and receiving a return under an enhanced bond investment by an Australian taxpayer from a UK bank. The Draft Determination was released on 24 October 2008 and comments are invited by 21 November 2008.
|Treaty Development|Australia- United Kingdom
Briefly, the arrangement involves an Australian taxpayer purchasing bonds (or similar securities) from a UK bank or financial institution. The bonds are acquired through a limited liability company (LLC), wholly-owned by the taxpayer and established in a jurisdiction other than Australia or the UK.
The jurisdiction of the LLC is chosen so that the payment of intere…
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