Many practitioners believe that the TOFA reforms involve issues that are the domain of the 'Big end of town'. However, the reality is that these reforms can also impact how SMEs are required to treat certain transactions for tax purposes. This paper addresses:
- what is the current status of TOFA reforms:
- debt/equity 'at call loans'
- foreign exchange gains and losses
- illustrative examples
- carve out rules for small and SME clients
- likely direction of future TOFA reforms around financial assets and liabilities.