‘Accrued’ Farm Management Fees Assessable
In an Administrative Appeals Tribunal decision, a company which had operated a tax effective investment scheme has been unsuccessful in arguing that it should have only been assessable on those fees received from investors for which the Commissioner had allowed a deduction for actual cash outlays. Rather, the Tribunal found the company, as an accruals taxpayer, had derived all the fees that it was contractually entitled to receive under the scheme, which included those non-cash payments arising from the round-robin loan arrangements entered into with the investors.
In an Administrative Appeals Tribunal decision, a company which had operated a tax effective investment scheme has been unsuccessful in arguing that it should have only been assessable on those fees received from investors for which the Commissioner had allowed a deduction for actual cash outlays. Rather, the Tribunal found the company, as an accruals taxpayer, had derived all the fees that it was contractually entitled to receive under the scheme, which included those non-cash payments arising from the round-robin loan arrangements entered into with the investors.
