Australia: Functional currency realization events on certain loan repayments
ATO updated its 2024 completed issues list
ATO updated its 2024 completed issues list
The Australian Taxation Office (ATO) updated its 2024 completed issues list with an outcome statement of its consideration to issue an updated draft determination to clarify the application of a “forex realisation event 4” upon repayment of a loan incurred prior to the effective date of an applicable functional currency choice and denominated in the same non-Australian dollar currency that later becomes the applicable functional currency.
The ATO states that on June 26, 2024, it amended the withdrawal notice (dated October 8, 2014) for draft taxation determination TD 2014/D10 Income tax, and that it will apply the view that forex realisation event 4 happens in the circumstances outlined in former TD 2014/D10 to gains and losses when the applicable functional currency election is made on or after June 12, 2024.
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