This session examines development company structuring through the lens of Taxpayer Alert TA 2026/1, which targets contrived property development arrangements between related parties that defer income recognition and exploit tax losses. The Alert is considered against earlier ATO integrity materials, namely TA 2009/5 and GSTR 2010/1, which address the use of associate entities to obtain GST benefits through non-commercial construction and invoicing arrangements. Together, these materials illustrate the Commissioner’s broader approach to substance-over-form, timing mismatches, and artificial separation of economic activities in property development.
Please see below link to case materials which is assumed reading in order to participate in the discussion:
Discussion led by Adrian Cartland