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Greenwoods & Freehills Pty Limited Consultation submission

[Redacted for publication]
[received as email 24 August 2011]

I would like to make a brief submission on the TFN provisions.

There is currently some ambiguity as to whether in the event of certain tax rollovers (for example under subdivision 124-M [scrip for scrip rollover] or 124-G [interposition of a holding entity]) or in demerger type transactions (specifically Division 125 or subdivision 126-G) it is permissible for existing listed groups to pass the TFNs they hold to their successor entities. It is administratively expensive and from a privacy perspective I suggest unnecessary for the TFNs to be requoted.

I submit that the new provisions should make it clear that in these circumstances the TFNs can be passed on.

I would be happy to discuss this matter if so required.

Kind regards


Joshua Cardwell
Greenwoods & Freehills Pty Limited
Direct [Redacted for publication]
Mobile [Redacted for publication]
Switch 61 2 9225 5955
Facsimile [Redacted for publication]