ARTICLE · 22 AUGUST 2013

Dividend Access Share Arrangements – Stripping away the uncertainty

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TD2013/D5 provides a detailed example of a DAS arrangement which the Commissioner would regard as "dividend stripping".

AustraliaTax

In July 2012, the Australian Taxation Office published Taxpayer Alert 2012/4, which highlighted the Commissioner's view that the use of Dividend Access Shares (DAS) may infringe a number of the integrity measures contained within Part IVA of the Income Tax Assessment Act 1936 (Cth) (ITAA 1936).

Almost one year on, the ATO have extended upon this reasoning by releasing TD2013/D5, which provides a detailed example of a DAS arrangement that the Commissioner would regard as constituting "dividend stripping" for the purposes of Section 177E ITAA 1936.

What Type Of DAS Arrangement Would Constitute Dividend Stripping?

The following is an overview of the facts considered in TD2013/D5:

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