The TOFA rules will have significant implications for many SMEs. Issues discussed in this paper include:
- the scope of the legislation - how wide is the definition of “financial arrangement” and what taxpayers will be impacted?
- a practical application of the proposed rules
- update on issues such as:
- FX denominated bank accounts
- short term foreign exchange gains/losses
- at call loans
- the continuing interaction of pre TOFA rules, existing TOFA rules and the proposed rules.