Date posted: 14/04/2026
Submission on ED0267 Returns of capital: Off-market share cancellations
Bright line tests and the Commissioner’s notice requirements and other matters.
Once finalised, the statement is expected to provide valuable guidance for taxpayers, practitioners, and Inland Revenue. CA ANZ has identified several areas within the draft that would benefit from further clarification to enhance certainty and practical usefulness.
In particular:
- References to the bright-line thresholds could be refined to more accurately reflect the legislation.
- The discussion on the application of the time-bar rules could be expanded to provide greater clarity.