The Taxation of Financial Arrangements (TOFA) Legislation: Is There Work Left to be Done?

Document Type

Book Chapter

Publication Date


Source Publication

Evans, Chris, and Richard Krever. Australian Business Tax Reform in Retrospect & Prospect. Pyrmont, N.S.W: Thomson Reuters, 2009. Print.


financial instruments, debt-equity boundary, debt-derivative boundary, market-value accounting, hedge accounting


The paper offers some general comments on certain of the broad design features of the Australian taxation of financial arrangements (TOFA) legislation. More particularly, the paper compares these features of the TOFA legislation with those of a comprehensive accrual regime. Although the TOFA legislation is broadly consistent with such a regime, it has some unique features that set it apart.


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