A joint professional body submission sent to the ATO in relation to the draft taxation determinations:
TD 2007/D14 Income tax: can section 23AJ of the Income Tax Assessment Act 1936 apply to a dividend when it is paid by a company (not being a Part X Australian resident) to an Australian resident company which receives it in its capacity as a partner in a partnership? and
TD 2007/D15 Income tax: can section 23AJ of the Income Tax Assessment Act 1936 apply to a dividend paid by a company (not being a Part X Australian resident) to the trustee of a trust, which then pays it to an Australian resident company beneficiary?