|
1. Chief Tax Counsel’s speech on tax litigation
On 24 July, in a lunch time discussion at Maddocks, ATO Chief Tax Counsel, Kevin Fitzpatrick, gave a speech on the ATO’s approach to tax litigation. Mr Fitzpatrick said that tax litigation is important for both the ATO and the community, that it allows disputes to be resolved and contentious areas of the law to be clarified. He noted that areas of the law which would benefit from judicial clarification are the consolidated groups regime, debt/equity rules, taxation of trusts and section 177EA involving franking credit schemes.
With regard to the ATO’s litigation practice, Mr Fitzpatrick said that one of the key principles in conducting litigation by ATO staff is presenting arguments that are consistent with the ATO’s existing published view of the law such as in public rulings. In addition, when expressing a view to a Court or Tribunal, the ATO representative should demonstrate that the view is based on a purposive interpretation of the law.
The Chief Tax Counsel also spoke about the test case program. He said that the number of applications for funding and the number of cases funded under the test case program have increased in recent years. In the 2007/08 income year, 13 cases were agreed to be funded out of 31 applications. In addition, the ATO will soon be releasing a revised test case program booklet which explains how the program works.
Other key topics covered in the speech included new federal court directions for tax litigation, alternative dispute resolution and settlements, and annual compliance arrangements (ACAs).
In his concluding remarks, Mr Fitzpatrick said that there is room for improvement in tax litigation in the areas of timeliness, focusing on the real issue and law clarification in areas of uncertainty.
Top
2. Small business CGT concessions: exposure draft legislation released
On 14 October, Treasury released exposure draft legislation (the ED Bill) on proposed amendments to certain aspects of the small business capital gains tax concessions.
More specifically, and as stated on the Treasury website, the changes in the ED Bill will 'increase access to the small business capital gains tax (CGT) concessions for taxpayers owning a CGT asset used in a business by a related entity and for partners owning a CGT asset used in the partnership business, with effect from the 2007-08 income year.
Currently, the small business entity test does not cover business structures where the CGT asset is owned by an entity but is used in a related entity which carries on the business. In addition, for partnerships, the small business entity test requires the taxpayer making a capital gain to be a partner in the partnership and for the asset to be an asset of the partnership.'
The Government announced in the Budget this year that its intention was for these measures, originally put forward by the previous government, to be introduced into parliament this year.
The ED Bill also makes a number of other amendments to refine elements of the small business CGT concessions.
Treasury is inviting interested parties to participate in consultation on the ED Bill and the due date for submissions is Wednesday, 26 November 2008. Members are welcome to e-mail any comments to Tax Group by 5 November.
The Institute has already been invited to meet with Treasury in Canberra on 6 November to discuss the ED Bill. We will provide an update on this in due course.
The ED Bill and accompanying Explanatory Material are available via this link.
Top
3. Mergers, acquisition and restructures: a speech by Senior Assistant Commissioner
Senior Assistant Commissioner, Deborah Hastings gave a speech entitled Mergers, acquisitions and restructures, at the 47th Victorian State Convention hosted by Taxation Institute of Australia. The Assistant Commissioner examined a number of capital gains tax issues that commonly arise in class ruling requests dealing with merger and acquisition activity. These include the rollover relief provided in the scrip for scrip provision (Subdivision 124-M), and demerger provisions (Division 125) in the Income Tax Assessment Act 1997 (ITAA 1997).
The speech also highlighted other potential and/or emerging risk areas, including specific areas in merger and acquisition activity which featured in the recently released ATO Compliance Plan 2008-09. In addition, two recently introduced ATO initiatives were discussed, namely, the ‘M&A Framework’ and applying the priority private binding ruling system to class ruling requests in merger and acquisition transactions.
In concluding her speech, the Assistant Commissioner said that in the past year, the ATO has consulted widely with advisors and practitioners engaged in merger and acquisitions work and in the coming year, the ATO will be looking to engage in further consultation in this area to enhance the quality and level of advice in both the ATO’s compliance and law areas.
Top
4. Submission on Australia’s Future Tax Review
On 17 October, the Institute and KPMG lodged a joint submission with the Australia’s Future Tax System Review Panel (the Panel) in response to its press release of 19 August. In the submission, the Institute and KPMG focus principally on options associated with reforms to the taxation of capital and, in particular, reforms to the Australian corporate tax system. Among other recommendations, the submission proposes a reduction in the corporate tax rate, improvement of the current dividend imputation system, and identification and implementation of international best practice on the taxation of capital income.
Our key submission points include recommendations that the Australia’s Future Tax System (AFTS) Review should:
- analyse Australia’s taxation of capital income regime and assess whether Australia has the right incentives for individuals to provide for their future and to provide capital to businesses
- examine whether Australia’s dividend imputation system should be retained or improved
- further evaluate alternate corporate tax systems in the Australian context. It is recommended that the merits of the following alternate corporate tax systems should be evaluated to determine whether such systems offer (in whole or in part) possible reform options. These alternate tax systems are:
- allowance for corporate entity
- allowance for shareholder equity, and
- dual income tax
- achieve greater leveraging off existing reporting systems
- consider the tax implications of other capital market reforms.
As reported in Edition 32/2008 of the Tax Bulletin, submissions received by the Panel and discussions held with interested parties will be used in developing a consultation paper which will be released before the end of calendar year 2008. The Panel will deliver its final report to the Treasurer at the end of calendar year 2009.
Top
5. Submission on the TOFA Exposure Draft Bill and related Explanatory Material
On 17 October, the Institute lodged a submission with Treasury on the Exposure Draft of Tax Laws Amendment (Taxation of Financial Arrangements) Bill 2008 (ED Bill) and accompanying Explanatory Material (EM). Our key submission points include the following:
- the accruals method is excessively complex and needs financial statements short cuts
- additional considerations are required in Division 230 to address emerging issues, such as the proposed carbon emissions trading scheme, and the appropriateness of the exclusion for certain “earnout” arrangements
- an alternative framework should be adopted by Treasury, instead of applying the entry history rule to Division 230 liabilities
- additional clarification is required as to the notion of a “report [that] properly reflects your affairs” used in the ED Bill.
The Institute also noted in the submission that as the ED Bill is expected to be introduced into Parliament before the end of the Parliamentary Spring sittings on 4 December 2008, there are certain complex issues, such as the interaction of the hedging election and tax consolidation, which may not be adequately addressed before its introduction into Parliament. Thus, the Institute welcomes any future opportunity to work with Treasury on those proposed amendments.
Top
6. Joint submission on draft Taxation Ruling
The Institute has lodged a joint submission, available on the Institute website, on the following draft Taxation Determination:
TR 2008/D6 - Income tax: genuine redundancy payments.
Top
7. Australia denied the right to tax gain on sale of shares in an Australian subsidiary under the ‘pre-CGT’ Swiss tax treaty - Virgin Holdings SA v Commissioner of Taxation [2008] FCA 1503
In allowing the applicant’s appeal, the Federal Court (Edmonds J) has held that Australia was denied the right to tax a gain on the sale of shares in an Australian subsidiary made by a Swiss resident company under the Agreement between Australia and Switzerland for the Avoidance of Double Taxation with respect to Taxes on Income [1981] (together with the Protocol) - ‘the Swiss Agreement’.
In brief terms, Virgin Holdings SA (Virgin Holdings) acquired shares in Virgin Blue Holdings Limited (VBHL) in June 2003 from a group company (which was followed by a share split, a share buyback and the sale of a small parcel of the VBHL shares). In December 2003, Virgin Holdings disposed of a large portion of its remaining shares in VBHL as part of an initial public offering. The Commissioner issued an assessment, then an amended assessment (increasing taxable income by around $193m) in 2007 seeking to tax the gain on the share sales for the year ended 31 March 2004, in lieu of year ended 30 June 2004. Virgin Holdings objected.
The Court found that ‘the Australian income tax’ in Art 2(1)(a) of the Swiss Agreement ‘accommodated and encompassed, at the time of the conclusion of the Swiss Agreement, the taxation of capital gains’, despite it being concluded prior to the time that Australia taxed capital gains on a comprehensive basis (ie pre-CGT).
The Court then turned its attention to Article 7 ‘Business profits’, referring extensively to the decision of the High Court in Thiel v Federal Commissioner of Taxation (1990) 171 CLR 338, which also concerned the Swiss Agreement and, in particular Article 7 and former s 26AAA of the ITAA 36. The Court concluded that Article 7(1) denied Australia the right to tax the amount in question. The Court then stated that if its conclusion on Article 7 was incorrect, then Article 13 on ‘Alienation of Property’ would deny Australia the right to tax the gain.
Broadly, the Court’s conclusion is contrary to Taxation Ruling TR 2001/12, where the Commissioner takes the position that ‘Australia’s right to tax gains taxable in Australia exclusively under the capital gains tax regime … is not limited by pre-CGT treaties.
Top
8. Legal expenses deductible under s 8-1(1) - Romanin v The Commissioner of Taxation [2008] FCA 1532
The Federal Court (McKerracher J) has held that legal expenses incurred by the taxpayer in the 2000 to 2004 income years were deductible under s 8-1 of the ITAA 1997. The expenses were in respect of proceedings instituted to recover income that was contractually due to Mr Romanin following the sudden termination of his employment in September 1999. Ultimately, in November 2003, the Industrial Relations Commission of New South Wales (the Commission) upheld Mr Romanin’s claims, awarding him 12 months remuneration (less his earnings from other work in this period), interest on that sum and an award of (most) costs in his favour.
McKerracher J stated (para 52):
‘In my view, the requisite connection exists between the outgoing claimed (legal expenses) and the incurrence of assessable income. On this point, I accept Mr Romanin’s submission that he pursued proceedings in the Commission to obtain income that was contractually owed to him and that the costs incurred in doing so are deductible under s 8-1(1) of the ITAA. As the majority of the Full Court has made clear in Day 164 FCR 250, the legal proceedings in question need not relate to the activities of one’s employment for the related legal expenses to be deductible under s 8-1(1)’.
The Court also rejected the Commissioner’s contentions that the outgoings were capital in nature and considered that recoupment of the majority of the legal expenses as a result of the Commission’s decision would be properly assessable in the year of receipt (being the year ended 30 June 2005).
Top
9. Commissioner’s exercise of power not for improper purpose or unreasonable - Uratoriu v The Commissioner of Taxation [2008] FCA 1531
The Federal Court (McKerracher J) has dismissed an application for judicial review in which the applicant sought a declaration that the garnishee notice issued by the Commissioner on his bank was invalid.
The applicant argued that the Commissioner exercised his power to issue the notice either for an improper purpose or in a manner outside of his power. The notice was issued pursuant to section 260-5 of Schedule 1 of the Taxation Administration Act 1953 (Cth) (the TAA), requiring the bank to pay the Commissioner the sum of approximately $7.2 million or so much of that sum as was available.
The Court held that the Commissioner’s decision was neither improper nor unreasonable. His Honour considered that the Commissioner’s statement of reasons clearly indicated that regard was had to all matters raised by the applicant. The correspondence exchanged also revealed that all of the relevant matters in the Receivables Policy were considered.
Top
10. Decision Impact Statement - DCT v Broadbeach Properties Pty Ltd & Ors
The ATO has issued a Decision Impact Statement (DIS) on the High Court’s decision in DCT v Broadbeach Properties Pty Ltd; DCT v MA Howard Racing Pty Ltd and DCT v Neutral Bay Pty Ltd [2008] HCA 41. As reported in Edition 34/2008 of the Tax Bulletin, the High Court allowed the Deputy Commissioner’s appeals, finding that proceedings under Pt IVC of the Taxation Administration Act 1953 initiated subsequent to the issuance of statutory demands did not impede recovery of the tax debts concerned. The DIS concludes that the ATO respectfully agrees with all aspects of the High Court's decision.
Top
11. Appeal update
The taxpayer has appealed to the Full Federal Court against the decision of the single judge in Asciano Services Pty Ltd (formerly Pacific National (ACT) Limited) v Commissioner of Taxation [2008] FCA 1401.
As reported in Edition 36/2008 of the Tax Bulletin, in that decision, the taxpayer’s claim for diesel fuel credits was denied as the court held that the purchase of off-road diesel fuel for use in equipment not located in or on a rail vehicle was not entitled to a credit under s 53 of the Energy Grants (Credits) Scheme Act 2003 even if it is used for a purpose incidental to the use of a vehicle in rail transport.
Top
12. Goods and Services Tax Ruling - Addendum
GSTR 2008/3A1 - Addendum - Goods and services tax: dealings in real property by bare trusts
Top
13. Taxation Determinations - Withdrawals
TD 35W - Capital gains: what is meant by the term 'renewal of a statutory licence' in section 160ZZPE?
TD 36W - Capital gains: when is a renewal of a statutory licence 'wholly or principally attributable to' the taxpayer's ownership of the original licence?
Top
14. Product Rulings
PR 2008/66 - Income tax: Gunns Plantations Woodlot Project 2009 - Option 1
PR 2008/67 - Income tax: Gunns Plantations Woodlot Project 2009 - Option 2
PR 2008/68 - Income tax: Gunns Plantations Woodlot Project 2009 - Option 3
PR 2008/69 - Income tax: Gunns Plantations Woodlot Project 2009 - Blended Option
Top
15. Legislation update
Tax Laws Amendment (Political Contributions and Gifts) Bill 2008 was passed by the House of Representatives on 13 October without amendment and it was introduced into the Senate the next day.
An interim report on the Tax Laws Amendment (2008 Measures No 5) Bill 2008 by the Senate Committee on Economics was tabled on 13 October. The due date for the final report has been extended to 10 November 2008. The Bill is currently before the House of Representatives.
Tax Laws Amendment (Medicare Levy Surcharge Thresholds) Bill (No.2) 2008 was passed by the Senate on 16 October with several amendments. The amendments increase the thresholds for payment of the Medicare Levy Surcharge from $50,000 to $70,000 for individuals (instead of $75,000 as initially proposed by the Bill) and from $100,000 to $140,000 for couples (instead of $150,000 as initially proposed by the Bill). In addition, it was proposed that the operation of the amending Act must be independently reviewed for each of the next 3 years. The new thresholds will apply from the 2008-09 income year. These amendments were passed by the House of Representatives and the Bill now awaits Royal Assent.
International Tax Agreements Amendment Bill (No 2) 2008 was passed by the Senate without amendment. It now awaits Royal Assent.
The report of the Senate Standing Committee on Economics on the Tax Laws Amendment (Education Refund) Bill 2008 was tabled on 13 October. The Bill is currently before the House of Representatives.
Top
16. House of Representative’s draft legislation program – 2008 Spring sittings week 6
The House of Representative has released its draft legislation program for the period 20 to 23 October and it is expected to resume debate on the following tax related Bills:
- Tax Laws Amendment (Education Refund) - 21 October
- Tax Laws Amendment (2008 Measures No.5) - 23 October
Top
17. Recent ATO publications
Booklets and publications
eLink 40/08 - Bulletin to inform tax practitioners of the most recent updates to ato.gov.au including a lead article titled 'Frequently asked questions about the lodgment program'. Issued on 15 October 2008.
Fuel tax credits - making adjustments and correcting mistakes - This guide explains how to change your claim for fuel tax credits on your business activity statement (BAS). It explains the difference between adjustments and mistakes, the types of adjustments and how to make them, and how to correct a mistake. NAT 15681.
National rental affordability scheme - The Government announced it will provide $622.6 million over four years for the provision of 50,000 affordable rental properties across Australia for low and middle income earners. Bills have been introduced into Parliament.
Fuel tax credits and GST instalments - This fact sheet provides information on how to claim your fuel tax credits if you pay GST by instalments.
Annual Compliance Arrangement (Income Tax) - Document provides general information on new products announced by the Commissioner in May 2008 specific to the large business market.
Borrowing money or maintaining an existing borrowing of money - new draft ruling - A draft self-managed super fund (SMSF) ruling has been released for comment. It is about the meaning of 'borrow money' and 'maintain an existing borrowing of money' under section 67 of the Superannuation Industry (Supervision) Act 1993.
Taxation of financial arrangements: overview - Overview information on the taxation of financial arrangements (TOFA) reforms with links to more detailed information on specific measures.
Minutes of meeting
NTLG minutes - 17 June 2008 - Endorsed minutes of National Tax Liaison Group (NTLG) meeting held on 17 June 2008.
Administration
Portal maintenance schedule - Scheduled downtime for 2008.
Activity statements and super contributions due - The Tax Office today reminded businesses that September quarterly activity statements and super contributions are due by Tuesday, 28 October 2008.
Transferring lost members register to ICP - How the processing of super lost members information in the Tax Office's integrated core processing system will affect super funds and members.
Superannuation
SuperUpdate October 2008 - This edition includes information about members exceeding the contributions cap, new outcome of lodgment report error manual, death benefit nominations, a new draft ruling on borrowing money, lost member statement paper forms and verifying compliance with unclaimed super money.
PSI Rules
Personal services business determination application - Apply to us for a determination to clarify if the PSI rules apply to you or not.
Working out if the PSI rules apply - companies, partnerships and trusts - Find out if the PSI rules apply by using the results test, 80% rule, unrelated clients test, employment test and business premises test.
When the PSI rules don't apply - companies, partnerships and trusts - Explains your tax return obligations for your PSI.
When the PSI rules apply - companies, partnerships and trusts - Explains the changes to your deductions, who declares the PSI, additional PAYG and tax return obligations for your PSI.
When the PSI rules don't apply - sole traders - Explains your tax return obligations for your PSI and what to do if you enter a scheme to avoid tax.
What is personal services income? - sole traders - Find out if the income you receive for the work you do is classified as PSI.
When the PSI rules apply - sole traders - Explains the changes to your deductions and tax return obligations for your PSI.
Personal services income terms explained - Brief descriptions of some terms relevant to personal services income.
Personal services income - basic information you need to know - Get the basics about whether you receive PSI and if the PSI rules apply.
Working out if the PSI rules apply - sole traders - Find out if the PSI rules apply using the results test, 80% rule, unrelated clients test, employment test and business premises test.
What is personal services income? - companies, partnerships and trusts - Find out if the income your business receives is classified as PSI.
Foreign Income Tax
Changes to foreign loss quarantining and foreign tax credit calculation rules - Update October 2008 - This information addresses certain measures relating to the Controlled Foreign Company (CFC) issues register - removal of foreign loss and foreign tax credit quarantining.
Foreign income tax offset rules - Address certain measures relating to the Controlled Foreign Company (CFC) issues register - removal of foreign loss and foreign tax credit quarantining.
FBT
Fringe benefits tax (FBT) - exempt work-related items - Explanation of when the provision of certain work-related items is exempt from FBT, and a list of items that qualify for the exemption.
CGT
Capital gains tax (CGT) rollover - This fact sheet provides information to statutory licence holders. Depending on how your licence ends and is replaced you may be able to defer all or part of your CGT obligations and rollover all or part of the cost base of your original licence.
Capital gains tax update 2008-09 income year - Update on CGT developments for the 2008-09 income year. Current as at 30 September 2008.
TOFA
Taxation of financial arrangements (TOFA) - The Review of Business Taxation in Australia included recommendations for the reform of the taxation of financial arrangements (TOFA). The Government will implement the TOFA reforms in stages.
Top
18. ATO’s 2007-08 Annual Report released
On 15 October, the ATO released its 2007-08 annual report. Highlights of the report include:
- Net cash collections increased to $270.9 billion, which was $20.9 billion (8.3%) more than last year, and $9.8 billion (3.8%) above Budget forecast
- $9.3 billion was provided in transfers and payments (not including GST input tax credits and income tax refunds), which was 0.4% less than last year
- 42 new legislative measures were successfully implemented, including the tax cuts
- $42.4 billion in GST was collected for state and territory governments which fully met the ATO’s commitments under the GST performance agreement
- More than 1.9 million self preparers have lodged their 2007 return electronically, exceeding paper returns for the second year running.
The report also noted areas for improvements, such as:
- The ATO’s Change Program had to be re-planned for the third and most difficult
Stage
- The ATO ran 4.4% over budget
- The ATO lowered some of its service standards (but increased some others).
A copy of the annual report is available on ATO’s website.
Top
19. Inspector General of Taxation’s annual report for 2007- 08 income year released
The annual report of the Inspector General of Taxation (IGOT) for the 2007-08 income year has been released. The report was tabled in the House of Representatives on 13 October and in the Senate on 14 October. In the report, the current IGOT, David Vos said that the role of IGOT has developed into an important link between taxpayers and their representatives and the ATO.
During 2007-08, the IGOT completed the following three reviews:
- A review of the potential revenue bias in private binding rulings (publicly released
5 February 2008)
- A review of the extent to which the ATO has implemented recommendations from
completed reports by IGOT
- A review into the ATO’s administration of GST audits.
At 30 June, the IGOT has five reviews underway:
- A review into the underlying causes and the management of objections to the ATO decisions (commenced January 2007)
- A fourth, summary report on the review of the ATO’s handling of complex matters arising from the three case study reviews completed during 2007 (commenced June 2007)
- A review into the ATO’s administration of public binding advice (commenced November 2007)
- A review into the non-lodgment of income tax returns (commenced November 2007)
- A review into aspects of the ATO’s settlement of active compliance activities (commenced November 2007).
A copy of the Annual report is available on the IGOT’s website.
Top
20. Transcript of the Public Accounts and Audit Committee hearing
As reported in Edition 38/2008 of the Tax Bulletin, on 3 October, the Commissioner of Taxation appeared before the Public Accounts and Audit Committee to explain how Australia’s tax system is being administered. The transcript of that hearing has now been released and a copy is available via the Parliament website.
Top
21. Treasury released submissions received on non-forestry managed investment schemes
As reported in Edition 29/2008 of the Tax Bulletin, on 1 August, the Assistant Treasurer and Minister for Competition Policy and Consumer Affairs, the Hon Chris Bowen MP, released an issues paper on the Review of Non-Forestry Managed Investment Schemes (MIS) which examined the economic, social and environmental impacts of non-forestry MIS.
Since then, Treasury has received 79 submissions in response, of which 75 are public submissions and 4 are confidential. The submissions that do not contain confidential material are published on the Treasury’s website.
Top
Chartered Accountants Tax Update for Business
Throughout November 2008 and March 2009 in Sydney, Melbourne, Adelaide, Perth and Brisbane. In just 3 hours, explore the current and impending legislative changes across all areas of taxation relative to business.
Chartered Accountants Managing the Payroll Function Workshop
Throughout November in Sydney, Melbourne, Adelaide, Perth and Brisbane. Legislative changes resulting from the Federal Budget have impacted payroll. Be able to confidently deal with the myriad of issues affecting you.
Chartered Accountants Trusts and Tax for Property Seminars
Throughout November in Sunshine Coast, Cairns, Mackay, Hobart, Launceston, Canberra, Albury, Moree, Dubbo, Port Macquarie and Lismore. Unlock the tax benefits in trusts. Analyse the key tax attributes of trusts and recent litigation developments, and learn how those tax attributes can be used effectively in a commercial environment.
Top
ATO and omitted income project
One member writes:
Yesterday I received an omitted income letter for my client. The client had apparently not included a travel allowance received in the tax return lodged for 2006. On enquiry she also indicated that she had not claimed the kilometres as a deduction to which that travel allowance related. I would have thought that this was a common occurrence and as it would have no net effect on the taxpayer, I would have thought that it would be reasonably simple to resolve.
I rang the ATO and said that I would put in an amendment request as they said that they could not accept this deduction over the phone. I was then told that I could not put in an amendment request, as it was part of the income matching project. I would have to wait until the amended assessment issues in about 28 days and then I could put in a request for amendment. I pointed out that if an amended assessment issues then I should put in an objection request to protect my client's rights and I could not see why my client had to incur the costs of an objection. I also pointed out that this process seemed to be against the taxpayer's charter in a number of ways. Interestingly enough the ATO officer did not understand the difference between an amendment and an objection. Is it not possible to get some common sense into this process from the ATO instead of wasting both their own and the taxpayer's time and money.
Top
Help us to improve the bulletin by sharing your tax issues and experiences that might be of interest to other members. Responses should be emailed to taxgroup@charteredaccountants.com.au
Disclaimer
The Institute has created and maintains this tax bulletin as a service to its members and the community. While some of the information provided is about legal issues and legislation, it is not legal advice. The Institute does not expect or invite any person to act or rely on any statement, view or opinion expressed in this bulletin, and readers should make and rely on their own inquiries in making any decisions or giving any advice.
The Institute accepts no responsibility for any errors or omissions contained in this bulletin, and disclaims all warranties with regard to the information at this bulletin, including all implied warranties of merchantability and fitness for a particular purpose. In no event shall the Institute be liable for any loss or damage arising out of or in connection with the use of this bulletin or the information contained in it, including special, indirect or consequential loss or damage, and whether such loss or damage arises in contract, negligence, tort, under statute, or otherwise.
The material provided in this bulletin is protected by copyright. Apart from any use permitted under the Copyright Act 1968, no part of any material may be reproduced or provided to the public or to any person, in any form or by any means, without written permission from the Institute or the relevant copyright owner.
Any information provided to the Institute in connection with this bulletin shall be provided by the submitter and received by the Institute on a non-confidential basis. The Institute shall be free to reproduce, use, disclose and distribute this information to others without limitation.
|
The Institute’s education and training pathway is the preferred choice for industry professionals.
Considering a career as a Chartered Accountant? Looking for the next step in your professional life?
The Institute is leading the debate in the areas that matter most to business and the accounting profession. 
The Institute produces an invaluable suite of tools, guidance, products and services to help members in their work. 
Print this article
Email this Article
