Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Actuarial deficit contributions to an approved superannuation fund are characterised by their purpose. Contributions made to bridge actuarially determined deficits, including prior-year deficiencies, are ad hoc gap-filling payments rather than ordinary annual contributions subject to the Rule 87 ceiling or initial contributions. Recurrence of deficits does not alter that character. Applying the ceiling to contributions necessary to meet actuarial liabilities could impair the fund's solvency and conflict with the deduction scheme for approved superannuation funds. On that basis, disallowance of the actuarial deficit contributions was deleted and the revenue's appeal failed.
Actuarial deficit contributions to an approved superannuation fund are characterised by their purpose. Contributions made to bridge actuarially determined deficits, including prior-year deficiencies, are ad hoc gap-filling payments rather than ordinary annual contributions subject to the Rule 87 ceiling or initial contributions. Recurrence of deficits does not alter that character. Applying the ceiling to contributions necessary to meet actuarial liabilities could impair the fund's solvency and conflict with the deduction scheme for approved superannuation funds. On that basis, disallowance of the actuarial deficit contributions was deleted and the revenue's appeal failed.
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