Tag Archives: Taxation Ruling

Bywater – justification for a changed view

On 21 June 2018, the ATO released Taxation Ruling TR 2018/5 (Ruling). The Ruling finalises Draft Taxation Ruling TR 2017/D2 (Draft Ruling), which was a response to the High Court’s decision in Bywater Investments Limited & Ors v. Commissioner of Taxation; Hua Wang Bank Berhad v. Commissioner of Taxation1 (Bywater).

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