The Australian Taxation Office (ATO) has finalized Taxation Determination (TD) 2023/5, Income tax: aggregated turnover and connected entities - Commissioner's discretion that an entity does not 'control' another entity. TD 2023/5 addresses specific issues that arise when the ATO considers whether to exercise the Commissioner's discretion to determine that one entity doesn't control another entity, which is central to determining whether entities are connected. The Commissioner has the discretion to determine that one entity doesn't control another entity if the control percentage is at least 40%, but less than 50%. This is important in relation to certain tax concessions where...