The amendments made to the non-arm’s length income rules to include the concept of non-arm’s length expenditure took effect from 1 July 2018. However, despite nearly four years passing, an ATO draft ruling, consultation period, finalisation of the ATO’s ruling, there still remains significant concerns on the wide reaching effect of these 2018 amendments and particularly the potential dire tax outcome for a superannuation fund that has non-arm’s length expenditure.
