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Tax Briefs

ATO Christmas present for private equity

On 16 December 2009 the ATO released two draft tax rulings on the main issues arising in its notorious recent court action involving the private equity group, TPG (though that case is not mentioned by name of course). The rulings effectively leave the revenue capital treatment and treaty shopping issues to case by case treatment, though making clear the ATO view of the TPG situation. For our full Tax Brief - click here