TaxBanter July 2026 Special Topic: Alienation, Professional Practices and Part IVA

Alienation arrangements where an individual’s personal services income (PSI) is derived through a personal service entity (PSE) that is conducting a personal service business (PSB) and profits are shared with related parties are at risk of being subject to the anti-avoidance provision in Part IVA.  

The Commissioner’s view about PSI, PSEs and PSBs is set out in 271 paragraphs TR 2022/3

Alienation arrangements where an individual’s personal services income (PSI) is derived through a personal service entity (PSE) that is conducting a personal service business (PSB) and profits are shared with related parties are at risk of being subject to the anti-avoidance provision in Part IVA.  

The Commissioner’s view about PSI, PSEs and PSBs is set out in 271 paragraphs TR 2022/3. Whether Part IVA applies to particular arrangements will always depend on the particular facts and circumstances – it will apply if a dominant purpose of the arrangement was to obtain a tax benefit. 

The Commissioner’s compliance guideline addresses aspects of an arrangement that may attract the ATO’s attention and hence raise questions about tax benefits and purpose. 

Indicators that are considered high risk and factors that will be a red flag to the Commissioner. 

Investment

Individual - $195 ex GST incl
Team - $585 ex GST (up to 6 team members)

If you do not already have an account, please create one here to:

  • Register a team
  • Access the 25% discount for the full year series!
     

Date & Details

Wednesday, 8 July 2026

11:00am - 12:30pm AEST (NSW, QLD, VIC, TAS, ACT)
10:30am SA, NT
9:00am WA

What we cover

On completion, participants will be able to:
  • Explain the basis for the Commissioner’s view that income of professionals cannot be split with family members 
  • Provide some reasons why the Tax Commissioner might be relying on the threat of applying Part IVA to arrangements entered into by professional persons/practitioners to rein in, what was perceived to be, rampant income splitting 
  • Explain the difference between income of a personal services business and income from a business structure 
  • Explain the two thresholds or gateways which an arrangement entered into by an individual professional practitioner should pass as a prerequisite to self assessing tax risk associated with a profit allocation 
  • Calculate the effective tax rate for allocations of a professional firm’s profits in accordance with the Commissioner’s PCG 2021/4 for an individual professional practitioner and their associates in a simple case   

TaxBanter Senior Trainer

TaxBanter are Australia's leading experts in personalised tax training. 
This webinar will be presented by one of TaxBanter’s experienced tax trainers.

Webinar

TaxBanter July 2026 Special Topic: Alienation, Professional Practices and Part IVA

08 July 2026 - 08 July 2026

Webinar

$195.00 + GST

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