Generally, the Taxation Institute supports the intent of the proposed amendments and recognises the need to address integrity issues. However, the Taxation Institute has some real concerns regarding:
- Multiple taxation of benefits not actually provided;
- Uncertainty caused by excessive reliance on the formation of opinions by the Commissioner of Taxation (Commissioner);
- The commencement and application of the proposed legislation;
- Fairness and equity concerns arising from the different taxation valuation methodologies applied to shareholders compared to employees; and
- Potential denial of entitlement to the Small Business and General Business Tax Break.