Title: Presenting the PricewaterhouseCoopers brand effectively
1pwc
2Department of Treasury and FinanceTax Knowledge
Centre DemonstrationWednesday 25 October 2000
3Department of Treasury and FinanceInteraction
of FBT and GSTWednesday 25 October 2000
4Seminar overviewPart One
- GST / FBT Basics
- Overview of the legislative changes
- Calculating FBT payable
- Reportable Fringe Benefits
5Seminar overviewPart Two
- GST Basics
- The new Amendment Bill
- Non-deductible expenses (Div. 69)
- Meal entertainment election
- Adjustment process
- Input taxed suppliers (Div. 71)
- Reimbursements (Div.111)
- Recipient Contributions
- FBT and the BAS
6Seminar overviewPart Three
- Impact on concessional fringe benefits
- Car Parking
- Exempt fringe benefits
- Impact on the types of employers
- rebatable
- exempt
- input taxed
- Impact on salary packaging
- Case study to reinforce major concepts
7FBT GSTThe interaction
8History of the changes
- GST Legislation received Royal Assent on 8 July
1999 - Variety of amendments passed and proposed
- Aim to ensure neutrality of the tax treatment
between fringe benefits and cash salary after the
introduction of the GST - Most have been introduced to address
practicalities - e.g. reimbursements
- Initial legislation and rulings to address the
interaction have not been completely successful - gross-up rates
9GST Basics
- GST, in most cases, is not an extra cost for
business - Where the entity is registered for GST it may be
entitled to input tax credits for the GST
incurred on an acquisition
10GST Basics
- Pre-1 July 2000 - Department incurs courier
delivery costs - 100.00 - Post-1 July 2000 - Delivery costs are subject to
GST - Cost is 100.00 plus 10.00 (GST)
- where the entity is GST registered entitled to
input tax credit of 10.00 - net delivery cost - 100.00
11FBT Basics
- Introduced to ensure tax is paid by the employer
on fringe benefits provided to employees/associate
s - includes . any right, privilege, service or
facility. - excludes (amongst others) salary or wages,
allowances, eligible termination payments - Person in receipt of salary or wages (current,
former and future employees)
12Types of fringe benefits
- Car
- Car parking
- Loan
- Housing
- LAFHA
- Expense payment
- Property
- Entertainment
- Meal entertainment
- Residual
- In-House
- Airline
13GST FBT
- From 1 April 2000 there are two types of fringe
benefits - Type 1 fringe benefits
- Type 2 fringe benefits
- Why two types of fringe benefits ?
- Necessary to ensure neutrality of the tax
treatment between fringe benefits and cash salary
after the introduction of the GST - TR 2000/D8
14Type 1 fringe benefits
- Type 1 Fringe Benefits are
- benefits provided to employees in respect of
which the provider of the benefit was entitled to
full (partial - motor vehicles) input tax credits
at the time the benefit was acquired. - Taxed as follows
- New FBT gross-up of approx. 2.129 applies
- Calculated as FBT rate GST rate
(1-FBT rate) x
(1GST rate) x FBT rate - Applies to GST-inclusive price of benefit
15Type 2 fringe benefits
- Type 2 fringe benefits are those that are not
Type 1 and include - benefits provided prior to 1 July 2000
- GST-free benefits (e.g. health insurance)
- input taxed benefits (e.g. residential rent)
- goods or services not acquired by the employer
(e.g. manufactured) - Existing FBT gross-up of approx. 1.942 applies to
GST-inclusive price
16Calculating the FBT payable
- Step 1 - Type 1 GST-creditable
- Calculate the total of individual type 1 fringe
benefits - Calculate taxable value of type 1 excluded
benefits - Add totals together
- Step 2 - Type 2 Not Type 1
- Calculate the total of individual type 2 fringe
benefits - Calculate taxable value of type 2 excluded
benefits - Add totals together
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17Calculating the FBT payable
- Step 3
- Multiply aggregate type 1 benefits by 2.1292
- Multiply aggregate type 2 benefits by 1.9417
- Add together to obtain fringe benefits taxable
amount - Step 4
- Multiply by 48.5 to get FBT payable
18Issues with two gross-up rates
- Transitional results
- Type 1 benefit will be subject to the lower gross
up rate for the period 1 April 2000 to 30 June
2000 - Compliance and administration
- Two gross-up rates
- Three calculations
- Form design changes
- documentation standards
19Group Certificate Reporting
- A New Tax System (Fringe Benefits Reporting) Act
1999 - Effective 1 April 1999
- Where taxable value of gt 1,000
- Lower gross-up taxable value reported
- Not reported
- exempt benefits
- otherwise deductible portion
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20Fringe Benefits on Group Certificates
- Do not include the value of
- car parking
- meal entertainment
- entertainment facility leasing expenses
- certain remote area benefits
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21Fringe Benefits on Group Certificates
- Superannuation Contributions Surcharge
- Medicare Levy Surcharge
- Income tested government benefits
- HEC
- Child support payments
- Termination payments surcharge
- Family allowance
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22Payment of FBT
- Normal FBT Remitters
- Instalment is 1/4 of preceding years FBT
liability where FBT payable gt 3,000 - Instalments reported for FBT
- 21 July, 21 October, 21 January
- Lodge FBT return 21 May
- Disclosed on BAS separately
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23GST issues
24Illustration - pre and post GST
The use of two gross-up rates aims to ensure that
after the introduction of the GST, there is no
difference between (1) an employee packaging
a benefit and (2) paying for the benefit
with after-tax salary.
25Entitlement of an input tax credit
- Acquired for a creditable purpose
- The supply is a taxable supply
- You provide, or are liable to provide,
consideration - You are registered, or required to be registered
26Meaning of creditable purpose
- To the extent that the acquisition is acquired in
carrying-on an enterprise - However, an acquisition will not be creditable to
the extent that - related to making input-taxed supplies
- is of a private or domestic nature.
27Taxation Laws Amendment Bill (No.8) 2000
- Confirmation of the treatment for entertainment
expenses - Specification of the requirements and treatment
of the meal entertainment election - Extension of treatment for input taxed suppliers
providing fringe benefits - Revising the rules for reimbursement of employees
for expense payment fringe benefits
28Non-deductible expenditure
An acquisition is not a creditable acquisition to
the extent that it is a non-deductible expense
- Penalties
- Relatives travel expense
- Maintaining family
- Leisure facility or boat
- expenses
- Entertainment
- Non-compulsory uniform
- Non-cash business
- Certain car parking
However, if it is a fringe benefit, it will be
deductible (but not necessarily creditable)
29Entertainment
Tax Deduction
ITC
FBT
Yes No Yes No Yes Yes
Entertainment - Employee off premises -
Client Entertainment - Employee in-house -
Client - Associate Sustenance -
Employee/client
Yes No Yes No Yes Yes
Yes No No No Yes No
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30What is Meal Entertainment?
- Provision of entertainment by way of
- Food or drink
- Accommodation or travel for providing
entertainment - Payment, or reimbursement of entertainment
expenses
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31Entertainment fringe benefits
- Does not include recreation that does not include
food and drink eg. golf days, theatre, football,
cricket matches - Does not include sustenance, light meals, working
lunch or dinner, meals while travelling - Eligible seminars, in-house dining facility,
entertainment provided under an industrial award,
promotion and advertising are generally deductible
32Entertainment fringe benefits (cont)
- Example
- Department (who provides taxable supplies) incurs
expense of 250 for 2 employees and 3 clients to
attend a business luncheon - Employee portion subject to FBT
- Income tax deduction only for employee portion
- Input Tax Credit only for employee portion
subject to FBT - FBT at higher gross-up rate
33Meal entertainment fringe benefits
- Division 69 (GST Act)
- Application may be different for Meal
Entertainment - Division 69 does not apply to expenditure for
meal entertainment expenses when an election has
been made (i.e.
50/50 split method or 12 week register method) - Therefore, Division 69 does not operate to deny
input tax credit for non-deductible portion of
meal entertainment - Identified in Draft Ruling GSTR 2000/D17 and
Proposed amendment.
34Meal entertainment fringe benefits (cont)
Department incurs expense of 250 for two
employees three clients at a restaurant
business lunch
- No election made (actual costs)
- FBT payable on employee portion
- Tax deduction for employee portion (which was
subject to FBT) - Input tax credit available only on employee
portion
- Election made (assume 50/50 split)
- FBT payable on 50 of total expense
- Tax deduction for 50 of total expense (which was
subject to FBT) - Input tax credit available on 100 of the expense
(subject to amendment)
35Meal Entertainment Election
- Proposed Amendment Bill
- make an election for GST purposes
- where make or withdraw the election at the end of
the FBT year, no need to amend BAS - classified as an adjustment event but will not
require an adjustment note to be held - Detailed process on when elections can be made
and the impact of the election
36Recipients contribution
- Payment from post-tax salary
- GST-inclusive amount of recipients contribution
reduces the taxable value - Where input-taxed or GST-free, no GST liability
- For taxable supplies, 1/11th of the recipients
contribution is payable as GST - Must determine if it is a part payment or a
periodic payment
37GST Attribution rules
- The liability for GST rests with the supplier
- The supplier is required to account for GST in
the period which is the earlier of - receiving payment or part payment or
- issuing an invoice for the supply
- A part payment will trigger the full liability
38GST Attribution rules - contributions
- Employee A has 100.00 deducted from each
fortnightly pay as a 2,000 contribution towards
a computer that is being salary packaged. First
contribution on 24 October 2000. - Department A will be liable for the full GST
liability upon receipt of the first payment - Department will be required to forward 181.81 as
part of its 21 November 2000 return
39GST Attribution rules - contributions - Periodic
- Employee A has 100.00 deducted from each
fortnightly pay towards the cost of a novated
lease motor vehicle that is being salary
packaged. First contribution on 24 October 2000. - Department A will be liable for GST upon each
payment for the periodic supply - Department will be required to forward 9.09 as
part of its 21 November 2000 return
40Financial suppliers (Input Taxed)
- Division 71 (GST Act) denies an input tax credit
for acquisitions used to provide certain fringe
benefits - Applies to entities that exceed the financial
acquisitions threshold - Acquisitions and importations that relate solely
or partly to making financial supplies are not
creditable acquisitions
41Illustration - pre and post GST - Input taxed
entity - Original Proposal
The use of two gross-up rates aims to ensure that
after the introduction of the GST, there is no
difference between (1) an employee packaging
a benefit and (2) paying for the benefit
with after-tax salary.
42Illustration - pre and post GST - Input taxed
entity - Amendments
The use of two gross-up rates aims to ensure that
after the introduction of the GST, there is no
difference between (1) an employee packaging
a benefit and (2) paying for the benefit
with after-tax salary.
43Financial suppliers
- If no fringe benefits tax would have been
payable(eg. Exempt benefits, 100 otherwise
deductible)Division 71 does not apply - Entities are required to review the actual and
intended use of the acquisition
44Illustration 1Division 71 (GST Act)
(In accordance with examples in GSTR
2000/D17) ABC Bank leases a motor vehicle and
provides the vehicle to Employee A who works
solely within the mortgage division
- Employee uses the vehicle partly for business use
- ABC not entitled to input tax credit on lease
payments - Lower FBT gross-up rate applies
45Illustration 2Division 71 (GST Act)
(In accordance with the examples in GSTR
2000/D17) XYZ Bank leases a motor vehicle and
provides the vehicle to Employee B who works
solely within the mortgage division
- Employee uses the vehicle solely for private use
- Vehicle not used to make financial supplies
- Therefore, Division 71 does not apply
- XYZ is entitled to full input tax credit on lease
payments - Higher FBT gross-up rate applies
46Practical Issue
Employee A works for the Department of
Infrastructure which makes taxable supplies
(grants) and input taxed supplies (residential
accommodation and rent) What criteria is used
to determine the treatment of a fringe benefit
provided to Employee A?
- The supplies made by the branch/division where
Employee A is located? - The supplies made by the Department as a whole?
- The employees actual duties?
- Need to consider the HR implications
47Reimbursements
- Division 111 (GST Act) attempts to set out
requirements - Employee, officer or agent must incur the expense
- Related directly to the employees activities as
an employee, officer or agent - GSTR 2000/D17 view
- Discussions with ATO
48Reimbursements (cont)
- Division 111 (GST Act) requirements (cont)
- Not creditable for the employer if not a taxable
supply, or employee, officer or agent is entitled
to an input tax credit - Input tax credit is apportioned for private /
domestic component unless expense payment is a
fringe benefit or an exempt benefit - Tax invoice must be in the employer or employee
name - pages 8-10 of the BAS Instructions
49Expense payment fringe benefits
- Example 1
- Employee A incurs 100.00 petrol expense on a
private car and is reimbursed by the Department.
The employee travels to departmental clients
(60) and also privately (40) - Private component (40.00) subject to FBT
- Expense partially relates to the employers
enterprise and other part is a fringe benefit - Employer entitled to full ITC
- Therefore, higher FBT gross-up rate
50Expense payment fringe benefits
- Amendment Bill
- Entities will be allowed an input tax credit for
all expense payment benefits - No entitlement to claim an input tax credit twice
51Expense payment fringe benefits - amendments
- Example 2
- Employee A incurs 100.00 petrol expense on a
private car and is reimbursed by Department. The
employee travels only privately - Private component (100.00) subject to FBT
- Expense is wholly private
- Employer entitled to full ITC
- Therefore, higher FBT gross-up rate
52Fringe Benefits and the Business Activity
Statement
- The acquisition of fringe benefits must be
recorded in the BAS - The relevant box in the BAS will depend on the
type of benefit acquired - for example - Car lease payments - G11
- Health Insurance Policy - G11 and G14
- Non-deductible expenditure - G11 and G15
53Fringe Benefits and the Business Activity
Statement
- Many departments are sourcing their BAS figures
from particular accounts - The allocation of fringe benefits acquisitions
may not be in accounts used for the BAS figures - Fringe benefits may be allocated to accounts that
are classified as wages and salaries and
therefore will not be included in the BAS - If the fringe benefit amount is not included in
the BAS, there will be no entitlement to claim an
input tax credit
54GST and FBT Summary
- Departments should
- review the GST and FBT treatment of benefits
- be aware of the changes in the legislation
- ensure that the correct amounts are being
included in the BAS and FBT amounts - review the TKC database and refer all unresolved
queries into that central database
55Questions
56Concessional fringe benefits What is the
impact of the interactionof FBT GST?
57An analysis of the following benefits
- Concessional fringe benefits
- Car parking
- Car benefits
- Exempt benefits
58Car parking fringe benefits
- Generally a taxable supply to the employer
- Externally provided
- Leased spaces
- Owned premises are potentially different
- Valuation method
- GST-inclusive value
- Number of days
- Transitional issues
59Car fringe benefitsImpact of GST
- Motor vehicles
- Removal of Wholesale Sales Tax from 1 July 2000
- GST at 10 from 1 July 2000
- Luxury Car Tax remains - 25 of value over
55,134 - Varying effects on running costs
- No GST on registration
60Car fringe benefits (cont)Transitional rules -
input tax credits
- Transitional rules - Denial of input tax credits
on new cars purchased - No entitlement to credits in 2000/2001 (ie. 100
denied) - 50 entitlement to credits in 2001/2002 (ie. 50
denied) - Full entitlement to credits in 2002/2003 (ie. 0
denied) - (Note implications for previously WST exempt
entities)
61Car fringe benefits (cont)Owned vehicles
- Owned motor vehicles
- GST on acquisition
- Partial/full input tax credit entitlement FBT _at_
2.129 - (i.e. cars purchased 1/7/01 onwards)
- No input tax credit entitlement FBT _at_ 1.942
- (i.e. cars purchased prior to 1/07/01)
-
62Car fringe benefits (cont)Leased motor vehicles
- Leased motor vehicles
- GST on lease payments
- Input tax credit entitlement FBT _at_ 2.129
- No input tax credit entitlement FBT _at_ 1.942
- Transitional period
- Pre-2/12/98 leases (relevant date where recipient
not entitled to full ITC) - Pre 8/7/99 leases (relevant date where recipient
is entitled to ITC) - GST-free until earlier of first review
opportunity or 1 July 2005 - Residual value subject to GST
63Car fringe benefits (cont)Statutory Formula
Method
- Statutory Formula Method
- Base value GST-inclusive value (including LCT)
- Transitional issues
- Leased cars
- two FBT gross-up rates (i.e. pre and post
1/7/2000) - Owned cars
- one FBT gross-up rate
64Car fringe benefits (cont)Illustration 1
- Statutory Formula Method
- Example
- Lease commenced on 1 April 2000
- Lease amount 35,000
- 20,000 kms travelled during FBT year
- ITC entitlement on lease payments from 1/7/00
- FBT liability Pre-01/07/00 35,000 x 20 x
91/365 x 1.942 x 48.5 - 1,644
- Post-30/6/00 35,000 x 20 x 274/365 x
2.129 x 48.5 - 5,426
- Total 7,070
65Car fringe benefits (cont)Illustration 2
- Statutory Formula Method
- Example
- Car acquired on 1 April 2000
- Base value 35,000
- 20,000 kms travelled during FBT year
- ITC entitlement on operating costs from 1/7/00
- FBT liability Total 35,000 x 20 x 1.942 x
48.5 - 6,592
-
66Car fringe benefits (cont)Operating Cost Method
- Operating Cost Method
- GST-inclusive cost of operating expenses
- ITC entitlement on operating costs - does not
determine FBT gross-up rate - Transitional issues
- Leased cars
- two FBT gross-up rates (i.e. pre and post
1/7/2000) - Owned cars
- one FBT gross-up rate
67Car fringe benefits (cont)Illustration 3
- Operating Cost Method
- Example
- Lease commenced on 1 April 2000
- Lease amount 35,000
- 20,000 kms travelled during FBT year
- ITC entitlement on lease payments from 1/7/00
- Operating costs (incl. lease payments) 15,000
(GST-inclusive) - Private use 40
- FBT liability Pre-01/07/00 15,000 x 40 x
91/365 x 1.942 x 48.5 - 1,409
- Post-30/6/00 15,000 x 40 x 274/365 x
2.129 x 48.5 - 4,651
- Total 6,060
68Car fringe benefits (cont)Illustration 4
- Operating Cost Method
- Example
- Car acquired on 1 April 2000
- Base value 35,000
- 20,000 kms travelled during FBT year
- ITC entitlement on operating costs from 1/7/00
- Operating costs (incl. deemed depn interest)
15,000 (GST-inclusive) - Private use 40
- FBT liability 15,000 x 40 x 1.942 x 48.5
- 5,650
-
69Exempt fringe benefits
- Example of an exempt benefit (laptop computer)
provided to employee - Cost of Laptop 1,100 Input Tax Credit
(100) FBT 0 Cost
to employer 1,000 - Where cost is salary sacrificed, employee
receives benefit - from pre-tax dollars and
- exclusive of GST
- Current legislation if wholly private, no ITC
entitlement unless employer incurs expense (New
legislation no restriction).
70Types of employers
71Rebatable employers
- Includes non-profit, non-government employers
(e.g. non-profit schools, clubs and associations) - Eligible for a rebate of 48 on the fringe
benefits tax payable - From 01/04/2001 - Rebatable limit
- 30,000 grossed-up taxable value per employee per
year - Tax effective to package benefits up to rebatable
limit - (however bear in mind, new tax rates)
72Exempt employers
- Includes public benevolent institutions, public
hospitals and non-profit private hospitals - Exempt from FBT on fringe benefits provided
- From 01/04/2000 - exempt limit
- 17,000 grossed-up taxable value per year for
employees in public hospitals and not for profit
hospitals - From 01/04/2001 - exempt limit
- 30,000 grossed-up taxable value per employee per
year - Tax effective to package benefits up to exempt
limit
73Input taxed suppliers
- Includes financial institutions
- Treasury area of company
- Division 71 - denies input tax credits on fringe
benefits provided (where FBT is payable) - Lower FBT gross-up rate applies
- Exception - where benefit is fully private to
employee or employee working in wholly taxable
area
74Impact on salary packaging
75Is salary packaging still attractive?
- Marginal tax rates lowered from 1 July 2000
- Employees currently earning 60,000 p.a. or less
will need to consider the continuing benefit of
packaging salary as fringe benefits - Employees earning more than 60,000 p.a. should
not automatically assume that packaging is still
worthwhile - The old and new marginal rates are as follows
76IllustrationImpact of lower marginal tax rates
- Car leased on 1 April 1999
- Leased amount 35,000
- Statutory fraction 20
- Operating costs (incl. lease payments)
- Pre-1/7/00 11,766
- From-1/7/00 12,590 (GST-incl.)
- Employer entitled to claim ITCs on lease
payments - Employees total package 60,000
77IllustrationImpact of lower marginal tax rates
78Is salary packaging still attractive? (cont)
- Exempt benefits
- No FBT
- Where input tax credit available to the employer,
benefit gained by the employee from packaging - ? Continue to package
- Benefits otherwise deductible
- No FBT
- Where input tax credit available to the
employer, benefit gained by the employee from
packaging - ? Continue to package
Current legislation - restriction of ITC
entitlement (Division 111 GST Act) where expense
incurred by employee and it does not directly
relate to the employees activities as an
employee New Bill - removal of restriction
79Is salary packaging still attractive? (cont)
Concessional benefits Provided to employees by
100 input taxed employers
Concessional benefits Provided to employees by
taxable employers
- Full cost of GST borne by employee on packaged
benefits - FBT valuation concessions remain
- Intention is that GST is recovered by way of
higher FBT, but - FBT valuation concessions may result in a lower
recovery of GST where input tax credits recovered
on expenses gt increased FBT
? Continue to package
? Continue to package
80Is salary packaging still attractive? (cont)
Non-concessional benefits Provided to employees
by 100 input taxed employers
Non-concessional benefits Provided to employees
by taxable employers
- Intention is that GST is recovered by way of
higher FBT, and - As no valuation concessions are applicable, GST
is effectively recovered
- Full cost of GST borne by employee on packaged
benefits
81Illustration Concessional vs. non-concessional
(1) Based on 100 days _at_ 10 (2) Average Cost 8
82Human resources issues to consider
- Allowances
- Pressure to increase amount (e.g. meal)
- Convert to reimbursement?
- Reimbursements
- Employers entitlement to claim ITCs
- Private business portions (current legislation)
- Packaging of additional Superannuation?
83Human resources issues to consider (cont)
- Employee inequity where multiple areas exist
- Salary package changes may be necessary to
prevent increased costs to employer - Employers should allow their employees to review
their existing salary packages to ensure still
tax effective (esp. where total package lt
60,000) - Effective communication of Tax Reform and
implications for employees - Changes to packaging arrangements must be
prospective
84Recipients contributions
- Payment from post-tax salary to employer attracts
GST - Recipient payments to third parties does not
attract GST - GST-inclusive amount of Recipients contribution
reduces FBT payable by employer - Contributions made pre-30 June 2000 will not be a
taxable supply - Where input taxed or GST-free, no GST liability
- Particularly useful for lower-marginal rate
employees
85IllustrationRecipients contribution
86Case Study
87Case StudyThe facts
Department A provides an employee with the
following salary-packaged benefits
88Case StudyQuestions to be answered
- Step 1 - Based on the facts contained on the
previous slide - Determine the employers entitlement to an
input-tax credit if - the employer is GST-taxable
- the area is 100 input-taxed
- the employer is FBT-rebatable
- the employer is FBT-exempt.
- Which FBT gross-up rate will apply to each
benefit provided?
89Case StudyQuestions to be answered
- Step 2 - Assume the employee has a total
remuneration of 80,000 (7,000 is paid as
contributions to superannuation) - How will the employees remuneration package be
structured?
90Case StudyStep 1 - analyse the benefits
Employer is
Employer is
GST-taxable
100 input-taxed
Input tax
FBT
Input tax
FBT
credit
gross-up
credit
gross-up
Benefit
entitlement
rate
entitlement
rate
4
6
Fully novated leased motor vehicle
2.1292
1.9417
6
6
Health insurance
1.9417
1.9417
4
6
Telephone account (private portion)
2.1292
1.9417
4
6
Professional membership
0.0000
0.0000
4
6
Car parking
2.1292
1.9417
91Case StudyStep 2 - impact on total remuneration
92Case StudyStep 1 - analyse the benefits
Employer is
Employer is
FBT-rebatable
FBT-exempt
Input tax
FBT
Input tax
FBT
credit
gross-up
credit
gross-up
Benefit
entitlement
rate
entitlement
rate
4
4
Fully novated leased motor vehicle
2.1292
2.1292
6
6
Health insurance
1.9417
1.9417
4
4
Telephone account (private portion)
2.1292
2.1292
4
4
Professional membership
0.0000
0.0000
4
4
Car parking
2.1292
2.1292
93Case StudyStep 2 - impact on total remuneration
94Questions and comments
pwc
95pwc
96Disclaimer
- Given that Australia is in the process of major
tax reform, there is considerable uncertainty as
to the breadth and ultimate impact of this reform
and, therefore, there is a degree of uncertainty
applying to any information provided at this
time. We have considered the legislation passed
to date, the current Bill before Parliament and
the draft rulings that have been issued at the
time of this publication. However, it is possible
that further legislation may impact upon the
information in this handout and any verbal advice
provided at this seminar.