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No, quite the opposite. The ruling relates to the specific fact scenario outlined in the document and you can see why the ATO came to the finding they did (see my previous post). So that particular tax payer is sorted. My point is that it is a big mistake to take a very specific scenario like...

So do retrospective tax payments and the related fines.

I can state with a strong degree of confidence that the ATO would have an issue with this scenario. Think about it this way: what logical explanation could be given that would convince the ATO that this arrangement was not primarily for the purpose of gaining a tax advantage? Compare and...