TIB - September 2009

Binding rulings

• Product ruling BR Prd 09/07
• Public ruling BR Pub 09/07: Provision of benefits by third parties – fringe benefit tax consequences – section CX 2(2)

Legal decisions – case notes

• Director to represent companies in appeal
• “Structured finance” transactions are tax avoidance arrangements
• No exceptional circumstances to allow a challenge outside the response period
• Decision to impose section HK 11 disputable
• Legal expenditure allowed if meets “principal purpose” test