Velocity Legal (00:03.23)
So this is Tax Talks, Australia's tax news podcast for accountants and tax practitioners. The podcast designed to help you grow your practice.
Velocity Legal (00:14.914)
Welcome to Tax Talks. it's August and we're here for the July updates. I'm your host, Rajan Verma. I'm your host, Andrew Henshaw. And today we're joined by Stacey Zalaga, director at Siva. Welcome. Thank you. It's great to be here. Stacey, you've had a quite a bit of experience in the podcasting world as well. yeah, a little bit. co-host a podcast called
Michelle and Stacey talking all things small business with Michelle Frayes, who's another public practice practitioner. Awesome. well, I guess today we're going to talk about the July, what's happening in July. And you know, one one big thing that happened in July was that it was the start of a couple of new regimes, both the anti-money laundering or AML regime and also the payday super. So
Maybe let's start with payday super. Stacy, I just wanted to get your experience from a practitioner's perspective about that that rollout and how it's how it's been. Yeah, interesting. Interesting. I think it's been one that had been coming for a while. we've been talking to clients about it for a while. it was originally delayed. Anyway, it's finally here and it's happening. I think the biggest issue is process and cash flow.
Is probably the two biggest pieces that we've seen for clients. So one, it's probably highlighted some clients where they haven't had the best process in place previously when they were maybe on a quarterly payment structure. And now it's gone to paying the super on payday. so yeah, so we've been able to help them, I guess, in getting ready for that. and also to make sure that they're obviously staying compliant with that too. and with any transition.
There's always hiccups and there's always things that happen a little bit differently in that first pay cycle, for example, than what will happen in the future ones. so yeah, so it's been a really, I guess, challenging time but interesting time to work with clients and really enjoy speaking to them and helping them through that. the cash flow side of things, wow, where do you start there? So most clients who have come off a quarterly
Velocity Legal (02:33.838)
Payment structure have now been hit with kind of like a double whammy because they're paying a quarterly amount plus fur, then they've kind of got to pay that first, really, before they pay that first payday super amount for the July period. So I think that's been a real struggle for some clients because some clients weren't expecting to pay, for example, that June quarter until the end of July, and then got kind of a bit.
caught out or surprised, even though we were trying to communicate this as much as possible. that, you know, that yeah, all of a sudden they had to sort of bring that forward a couple of weeks. That's that that's that double hit. So April, May, June, lodge on a quarter, normally you'd pay by the end of July. Now all of a sudden they ran a payroll at the start of July and then all of a sudden they've got to deal with it all then in a double hit. Yeah. Ex Exactly. Have you had because I understand with Payday Super that the
The super has to be paid in accordance with the employer's pay cycle. Have you had any inquiries about employers wanting to shift their pay cycles to be perhaps less regular than they normally are? Some, yes. and they're there have been really interesting conversations actually, because some, depending on what industries they're in, some they're not able to actually change it. so for example, like those in hospitality as an example can't change it. Like they're
per per the the award and things they actually need to be paid weekly. So because of that we haven't been able to, you know, make any changes. So yeah, so it's extra when I was talking about process before, like it's extra compliance, basically, that they've now got. Yeah, absolutely. I suppose the other aspect with Payday Super is is how the the the whole regime around SGC and you know how that's sort of going to play out moving forward.
I suppose. Well, hopefully with that, that you sort of the days of seeing these big you know, non compliant ones over years with these massive penalties and all that, might hope that that would be less. And I don't know under the new regime it's bit more there there's a bit more concessionary n aspects to it. So we'd hope that that's those days are gone. And I suppose also just catching it sooner. So you can
Velocity Legal (04:56.012)
You can deal with it quickly as opposed to dealing with multiple quarters that have been discovered. Yeah. You would hope so given the automations that, you know, are basically in place because the ATO now know because you're lodging your payroll with STP, so single touch payroll, they're getting that data. They're getting that data every time you have a pay cycle. So you would hope that they would be on it and catching it and trying to help people do the right thing. Cause I do believe that.
There's so much for small business out there, you know, so many compliance things that they've got to do that I don't think majority of them are on purpose trying to do the wrong thing. They've just got they're juggling so many things that things just get missed. Like, you know, we're human at the end of the day. The people running these businesses are human as well and things can just get missed. but this is why process is really important.
So if they've got some really good processes in place, then hopefully that should help catch catch those things sooner as well. But from the accountant's perspective, are there any particular challenges that you've observed? So putting aside the client challenges and maybe they maybe they are the challenges you're having to deal with, but are there any other challenges that you've had to that you've experienced in in the transition? not real. They're really around process and cash flow.
are really the two biggest ones that, yeah, that we've really seen and had to, yeah, tackle with clients. and some some are easier to tackle than others. we had been talking to clients quite a quite a way ago, like months ago, in the lead up to it, to sort of see do they actually have the cash reserves to be able to do this? Or should we maybe be looking with them at getting some finance and even if short-term finance
to just get through that July hurdle. and there were some clients that we were able to do that with because we acknowledged, you know, that that was something that was going to be needed. And there were some clients that we'd sort we'd worked out through cash doing some cash flows with them in advance that, yeah, it's probably going to be tight. But some clients either didn't want to go down that path and were sort of confident that they'll make it work. Or some that just
Velocity Legal (07:12.29)
their their business wasn't in a great space at that time to get extra funding. so yeah, so we are seeing some of those crunch times now happening. Maybe let's move on to the other one. AML compliance. you've grown. I I remember seeing a couple of funny I don't know if you saw any of these, but there was a couple of real estate agent posts about, I don't know, like I I'm gonna
I'm gonna make fun of it, but essentially it's I went to I went to high school and didn't go to university and but now the government said that I'm the you know the the the controller in chief of of anti-money laundering, policing it, et cetera, et cetera. so I think I don't I haven't seen any of those from lawyers or accountants, but but we're all dealing with this this new regime. We are all dealing with this new regime. And I think the the concept of it, like I s I support.
Do you do what mean? Like it is to protect our system and it is to make our system better. The annoying part, I guess, of it is, is that it feels like us as accountants, running accounting firms, are now we've just got this extra piece of compliance that we need to do. and who's paying for it? Like this is our time that we you know we now need to do some more checks and balances.
before we can do work with our clients or ongoingly the work that we're doing with our clients. And, you know, what do we do? Do we put fees up? Like why's that how's that fair on the client? You know, but then how's that fair on us as as business owners? Like we're running our business too. So it is a really fine balancing act, that kind of piece. And there's we already do so much training each year to keep up to date with everything that's going on. this is another piece of
you know, training that we need to not only train ourselves but our staff on on what to do and how to do it. So it's yeah, it it is a it is a really challenging one to be honest. but I just have to keep reminding myself that this is to make things better. Are you as a sort of because I know there's from a for accountants, there's sort of like a grandfathering process if you're sort of doing the same services.
Velocity Legal (09:34.518)
I've spoken to some people, they're sort of wanting to do that, others sort of saying, look, we'll just do every the you know, everyone, or what's your sort of take on on that? Yeah. So our take is is there is the grandfather grandfathering provisions there in place. And so we are utilizing that. So if we have provided that designated service to an existing client before, we're using those grandfathering provisions. That doesn't mean though, that that client's completely off the hook.
And we don't need to worry about them at all, we still need to make sure that any new service, any new designated service that they take up, that we're doing all those checks and balances for. And even if they are or they don't take up any new designated services, but we've still got these old designated services that we're providing. we do need to make sure that when we are providing those services, that we are still doing our checks and balances to make sure that, you know, they're still
a a person that we want to be dealing with and they're still doing all the right things. Because otherwise, unfortunately, we have reporting obligations. So yeah. So it's just a whole extra piece that, you know, you've got to have in your head when you're talking to clients now. and make sure that you're asking, you know, the right questions and enough questions and documenting, you know, extra things to make sure that, you know, we're we're all
being protected. Yeah. I suppose, yeah, I could see I mean for for for us as lawyers, I mean, almost every client interaction we have is new. w our relationships are not quite as enduring and longstanding as as as an accountant would be. So I guess there'd be a real challenge in that if you've got a client that you've been working for for 10, 15, 20 years, or you're dealing with the next generation perhaps, you know, trying to manage and keep on top of the AML compliance
And what might change over those years, it it would be a real challenge, I'd imagine. It is a real it that is a real challenge. And I think I think for accounting firms, some accounting firms might try to argue that we're, you know, we're not we're not bound by these rules. and try and like say we're not gonna offer any of these designated services. The reality is though, that as soon as we as soon as we are the registered
Velocity Legal (11:55.414)
office for a client wherein like w you you're offering a designated service and and you need to comply by those rules. it's interesting the point that you made before about family groups. So you might have known mum and dad for thirty years.
They've obviously raised some children. Those children may be the successors of these family businesses, and you may then be dealing with these children. These children, you would hope, have the same values as their parents and have been raised that way, but you can't be sure. Do you know what I mean? and you'd want like you'd want to hope so. And as a parent myself, I would definitely hope that my children have, you know, the values that I've taught them.
But under the AML rules, that's not, yeah, I know the parents, it's cool, tick it off. You've got to know that individual. So you do need to go down the path of then really getting to know who your client is. So your new client in that scenario is now the children. And yeah, that that it takes some time and it can be challenging. And I don't know, there's just different ways that, you know, that generations do things differently.
And so, yeah, constantly having to yeah, I guess be up to date with what's going on, whether it's through the parents or learning from the children yourself. and yeah, and how they operate. It's just, yeah, everyone thinks differently. And I suppose what would happen if say you you s you've sold your accounting practice and there are people who are retiring out of the profession and you buy a new accounting practice, so a young practitioner comes in and all the clients are new to them.
would they need to run new like AML checks on all the existing clients because the the advisor is new to the practice? This is a fabulous question and your timing is somewhat amazing. so we have actually recently acquired another accounting business. and this was like happening in the lead up to AML.
Velocity Legal (14:06.54)
Yes. And so we actually had to go down the path of finding out these clients that we are acquiring by acquiring this accounting this other accounting firm. are those clients new clients to us or are they existing clients to us? So given our transaction was on the 30th of June, these clients were deemed to be existing clients of our business for AML purposes. So
But that was because of the date of that transaction, right? So if it had been one July. That could have been a different outcome. Yeah. arguably maybe one July might have s you know, depending on, you know, your lawyers, so depending on the other terms and, you know, what's written in the agreement may have still been okay. that's probably a bit of a great area to be honest, especially with something that's so new and coming come into place. but to go to your question.
where say we do this again in six months' time, where we're not right on the cusp of which side are we on and is it gray or not, these clients, those clients would be deemed to be new clients to the firm. So yeah, so you'd have to go down the down the path of actually checking because it's from an AML perspective, it's the accounting practice that needs to be sure that they can tick those things off. And if
They're offering those designated services to those clients. So as soon as you're offering a designated service to a client that you have not offered that service to before, you're you're in and you've you've got to then do all those checks. I suppose it really adds another dimension to the to the transitional period that would usually happen when a when a when a firm changes hands, because the AML compliance would be another element to that, another aspect to that that would need to be managed with those clients.
Definitely, that'd be another part of the due diligence, I would imagine, is you know, to actually go through with that practitioner, the existing practitioner with each one of the clients. Had there been any of these sorts of issues, you know, you it's another whole thing to add to your due diligence list. Wow. Okay. Well, we're only one month into the AML. So I suppose some of these issues will play out as time goes on. Of course. Of course. Yeah. I think to your earlier point on payday super, it's it's process and cash flow. Process and having a process.
Velocity Legal (16:34.634)
It's not quite cash flow, but it's sort of who's gonna pay for, you know, this extra stuff that needs to be done. Yeah. Yeah. Well, let's move on to another sort of area of yes, some some controversy. the the I suspect we'll be talking about this a lot on the show over the next couple of years. We've already talked about it a bit, but the minimum tax on discretionary trusts. Now we had a in July, there was a consultation paper released.
and that closed for consult at the end of July. we'll get stuck into sort of I guess some of the things in the paper in a minute, but Stacy, I just wanted to ask you to start with, I guess, what's your what's your feel and take and what are you hearing from people about the whole 30% tr tax on trusts? Yeah, I think we've had we've had a lot of questions from clients. And what we're we've just tried to calm them.
little bit too, right? 'Cause they're reading the headlines, right? And the media hyp. And the media doesn't always you know, say things in ways that don't sound alarming. Like, you know It doesn't sell that that doesn't sell. Yeah. No. So so yeah, when they come to us, it's you know, am I gonna have to pay more tax? Should I be restructuring? You know, all of these sorts of questions like just calm down. First of all, it's not law yet.
It's an idea. Like, you know, because you gotta like talk their language and what they're gonna understand. so they're probably the two main things that, you know, they've been alarmed about is am I gonna have to pay more tax? Should I be restructuring? Calm down. Calm down. Let's just see, you know, I'm always the devil's in the detail. So let's just see what actually ends up happening. it was also very interesting to see that that when it went to parliament, that wasn't in
the bill, the first bill that went to Parliament, right? So they put everything else forward and held that one back. There's probably a reason for that too. so I think, yeah, I think, yeah, it it'll be interesting to just sort of see how how this all plays out. Yeah. Absolutely. I think there's a I think there's a sort of wise words that a and something similar I'm saying to people that just just it's two years away. you can wait a little bit. Sometimes where they can't, where they're sort of setting up something now or
Velocity Legal (19:01.666)
Maybe it's a property deal that's completing. But outside of those situations, you know, two years is a long time. A lot can play out. Yeah, that's right. If you've got an existing business and there's no other compulsion for you to restructure, I think waiting and seeing is a sensible approach. It would be interesting to see. So when they do the consultations, they do, I believe they always do publish, unless you sort of mark it as a confidential, they do list all the all the submissions that are put in. And I I do hope personally that there is a lot.
Velocity Legals put one in just just to sort of throw throw the hat in the ring. sort of think with these, a lot of people say, well, what's the point? but if you don't at least try to, you know, make your voice heard, then you know, you you're foregoing that opportunity. So absolutely. And I think a lot of a lot of the accounting professional bodies as an example are also putting in submissions. That's all CPA's one. I it was forty two pages.
I think ours was about seven or eight. But the CPA one looked very looked very sort of well considered and and and detailed. Yeah. I guess the real challenge is that when you read the consultation paper it very much in the and the questions, it was very much guiding you to a particular framework. So it's almost like we're building a house, the frame is already up. Yeah, should we use red bricks or blu or black bricks? That's that's right. So it it's kind of it yeah. I mean I know that I certainly the submission that we
Lodge was a little bit like, hang on, can we just have a more of a grassroots think about this? but yeah, I'm I'm a little bit concerned, given the way that the consultation paper was drafted, that it might be more set in stone than perhaps we we realise. I just think, you know, the taxation to trust is you know, it's so hard and so complicated. And we've got very old legislation, which is division six, and a lot of messy concepts in there, like what's the trust law income? What's the
tax law income, you know, who's entitled. There's so much stuff there to start with. Then we've got streaming rules, capital gain stuff. and the list sort of goes on. Then we've got sort of what's a family trust election and just there's so many already existing things that why add on top of that without kind of redoing the the whole thing? that's my I completely agree with you.
Velocity Legal (21:28.268)
All of those provisions that you've just mentioned, I feel like a lot of those are band-aid fixes for a whole heap of things. So it's like we're at a point where the whole thing needs to be scrapped and start again. Yeah. And I think also like with the 30% minimum tax, like in one sense, I I I I see where they're coming from and I can see that by having that in there, you could actually rationalise a lot of other provisions.
But one of the disappointing aspects about a consulting paper is that the 30% tax would sit on top of the existing division six. So you've got the complexity of working out your distributions and your proportionate approach, but by the way, the trustee pays 30% first. And then there's very little to nothing that's said about Division Seven A, one hundred A. like all these provisions that we're dealing with, sort of minimizing taxes by streaming distributions in a sort of perhaps in an inappropriate manner.
Does any of that really matter if the trustee's paying the thirty percent? Yeah, I think I think that's that's sort of one of one of points. It's if you've got to have something that's a flat line, surely the the the trade off is you get rid of a bit of complexity at the same time. But this doesn't no none of the questions are are about that. That that the you know, what's the trade off on this? It's all okay, we're gonna do this extra thing and you know, what's the definition? What should a discretionary trust be defined as, for example?
So yeah, it's very yeah. I like the analogy of building the house and it's you know, it's about what which material. Yeah. Should we do this at all? That's right. Yeah. Yeah, no, definitely. I actually wonder how much time and effort have they put into actually thinking about how to construct this. Well, I think one of the things there, I mean, on that time and effort is and one of the one of the things I'd like to chat about is the these these distributions to bucket companies.
Right. They've said, okay, the trust will get credit, the beneficiary will get a credit, non-refundable credit for the tax paid by the by the trustee. And you think, okay, well, that's okay, that's fair enough. until you realize that that a company can't. And essentially what they said was, well, if the company could get a credit, there might be a way of that company then, you know, declaring a dividend, and then someone will get the
Velocity Legal (23:51.426)
The the the like a like a refundable franking credit at the end of it. So it sort of defeats the scheme where the trust had to pay the tax in the first place if someone can ultimately get the refund. And what they said, and at least they were honest about it, they said the simplest way would be just to deny the bucket company a credit at all. Yeah, but it's completely unfair. It's completely unfair. And and to be honest, you could have made it fairer by simply amending the franking credit precisions to s to say that, well.
the the the receipt of that trust distribution doesn't generate franking credit yeah in the franking account. That that would have been perhaps even simpler. So to your point, Stacey, how much have they thought about it with that? I mean, I don't think they I don't think they really have. They just said, well that's the easiest. Yeah, okay, that's the easiest, but is that a good system? I think so. Yeah. Ex I I I don't know. That it's some of it just yeah. Some of it blows me away. And some of it I think some I think they do think about things. And sometimes
They it just seems rushed, you know. It's like, we've thought about all these other bits, we get all those bits out, and then we got to get to this bit. And yeah, yeah, that that sounds good. Let's just do that. Let's, you know, or see how far we can go with this and see. And the thing is, a lot of clients don't understand this stuff. So they're relying on the accounting professional bodies, tax tax agents, accountants, lawyers.
to fight this battle for them. and I think and as much as we want to do that, who's it really hurting at the end of the day? The small business owners. Yeah, that's quite right. There there was an interesting point. So I I I know that like the in terms of the broad framework, we kind of knew okay, thirty percent minimum tax, bucket companies don't get the benefit of that. But there were a few other little bits and pieces in there which I found interesting. So for one, you can't use the thirty percent minimum tax to offset the Medicare levy
Surcharge. Now I don't know if that was something that was said before and I missed it or if that's a little nugget that was put into this paper. but I was a bit surprised by that. I thought, Well why is that the not a tax, it's a levy or it's a surcharge. So so that was so that was one thing that I learned something today. That's good. So that so that was so yeah, apparently you can't offset the the the Medicare levy surcharge. So it's not just the thirty percent, but you
Velocity Legal (26:18.424)
have to pay that extra Yeah, so it's really not a thirty percent tax. That's thirty thirty plus percent. Yeah, that's right. Yep. so there was that. sneaky. A bit sneaky, yeah, a bit sneaky. there was a comment about the div seven A and and and and Bendel they they referred to this was more of an aside, but they referred to I think there was a a consultation paper or or a budget announcement back from t
Think it back from 2019 or or thereabouts, which it just basically sat there. you know, for a long time. Nothing's happened with it. And so they're now considering that, well, do we do we bring UPEs within Division Seven A? And my thoughts on that are does it matter? Like if there's a thirty percent minimum tax, why are you why are you worried about Div seven A now? Yeah, it was a bit cute. It was sort of saying
It's kind of a bit of a bookend to the consultation paper. It sort of said, Well, look, we note the high courts made this decision in Bendel. And we also note that the government, previous government, made a an announcement that they were going to bring UPEs within Division 7A back like five plus years ago. We just want to tie those things together now, essentially. But it but it yeah, it kind of misses the point that.
i if if you've got the non-refundable credit, I mean you wouldn't advise any clients to distribute to a corporate. so what's the point? So what's the point? Why why spend any energy energy on it? Yeah. Yeah, it's it's just not well thought out. I think that I think that's that's a good point. One question I've been getting a lot of is around trust losses and it'd be good to get your both your thoughts on on these as well. because
you know like how the tr like trust losses work. for about 30 years now we've sort of had a regime where it's sort of like well so long as it's within the family and there's issues about family trust elections, but so long as within a group and they've got your your elections right, you can use your losses within your groups. You know, it's like a fire extinguisher. You put it, send it wherever you need to basically. That's kind of how it works. It's
Velocity Legal (28:35.63)
Simplified, but that's kind of how it's a great analogy. and and there was sort of like a framework in place to make sure that you know there was no sort of more mischief where you know rid of the family trust election rules without with that framework. But my read of if you put this in is that it it really makes it very difficult to to sort of do that fire extinguisher type approach to losses. Yeah, well.
That's right. I think my my understanding is that if the losses are in the trusted question that's earning the income, then it's it's okay. Like you can use them there. But if you're trying to distribute from a profit trust to a loss trust, well the profit trust will pay its thirty percent minimum tax, non refundable of course, that pr money then moves into the second trust. Now the credit for the minimum tax won't mean anything because that other trust has losses. so
Yeah, I think it it it sort of allows the government to collect a clip and effectively devalues the use of those losses. The only time I could see you sort of using it in that scenario is you go loss you let's say you go trust A to trust B. Trust B has losses, and then trust B goes to an individual, let's say, and you you put so much money through this thing that it still results in the individual having exactly a 30% tax, 30% plus Medicare.
tax on the whole thing that you've sort of kind of dripped through that that difference on the losses, but I don't think that's gonna be really practical or workable to anyone. So and I don't think it's gonna be that common. No. I I guess the thing is that the upshot is that in future with around your general trust planning and end of year planning distributions and whatnot, it's not quite as straightforward as it
I mean, it was already complicated with the family trust elections and whatnot, but now you've got this additional element of thinking, well, are we actually going to be able to benefit from the use of those losses? Number one. But the other interesting thing too is that, well, what if you've got losses from five years ago that you still work, you know, using up? Suddenly from you know, and you might still have summers at one July twenty eighth, and then all of a sudden now those losses are caught up in a regime. So there's a there's almost an element of retrospectivity to it.
Velocity Legal (30:59.032)
Well, I think it goes to the more fundamental question that, you know, the whole reason the family trust election started in the first place was because of losses. If you're going to say losses are not available, do you even need a family trust election regime? Because there's so many problems with it at the moment, which are being ignored. You don't even need it. I mean, maybe you need it for one of those other purposes, but really the main reason around the family trust elections provisions were losses. That that was why they started in the first place. It's a really good point.
It's a really good point. Cause the other main reason we use them is for franking credits. Yes. And even that, that's a sort of a statutory, 'cause I mean it's a forty five day holding rule stuff and it's like, well, it's not really much mischief there. Like it's it's a family at the end of the day. Like where the where are the franking credits really gonna go? And there's I think there's other provisions to deal with that, any like avoidance rules that would apply to some type of dividend streaming or stripping anyway. Yeah.
But I suppose the thing is if you were if you were making family trust elections just so you could use losses, you might want to rethink that decision mu moving forward because the obviously the sting in the tail with the family trust elections is the the potential exposure to family trust distribution tax, which has become a more of a prevalent issue lately. So, you know, you may be advised not to make a family trust election to avoid the risk of that.
Family trust distribution tax arising in the future. Absolutely. One question I wanted to I wanted to sort of touch on one of the other parts around discretionary testamentary trust. I don't know, Stacey, if you've got a lot of clients asking about this, but I said, let's say I'm let's say I'm coming to you, Rajan, tomorrow and I say, Look, can you do my will? I know you're a tax lawyer, but can you do my will? and I want a testamentary trust. How are you drafting it? What are you what are you putting? Are you putting companies in or trusts or are you how how are you doing it? Well, I
Based on what the consultation paper is saying, the answer would be no trust, no companies. Because from my understanding of what they've said here that well, initially they said that the discretionary testamentary trusts were caught up in the minimum tax. Now they've kind of flipped on that, as they've flipped on many things. Carve outs, yeah. but I think they I believe they said in the paper that, well, it's gotta be all individual beneficiaries to be excluded from that measure. So if you've got companies and other trusts in there,
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be a problem. And then I guess if this if that changes in the future, you know, am I coming back to you to then change it again? Or it's or what if I did my well, you know, two months ago? Am I should I should I be, you know, changing it now? It's it's it's very difficult. It it is it is very difficult. And I I guess the other thing too is that once a person passes away, you can't really change change it. So
you know, there are people that are locked into into positions and you know, they've prepared their wills, they've done it based on the law at the time, and they've passed away. That trust is locked in now. the law's been changed and yeah. I I just think it's really hard to your point, Stacey, about the legislation. It's actually I think it's it's sort of like when a c when when you get something that's been
done by someone who is not doing it right. And then you have to say either we do it from the start or we kind of try to fix yours. And then you you say, look, it's actually gonna be harder to sort of fix this rather than just start again. and I feel like that's it's almost that situation. I agree. And look, I think there can be some client s just say hypothetically this goes through, right? I think there can be some s client situations where EU
Say the trust owns property. If you're to move that from that trust into another entity, there's gonna be stamp duty and a whole, you know, a whole heap of other on costs, if you like, flow on costs that aren't just related to 30% tax, right? And it'll be weighing up. There could be some scenarios where it actually, yes, you're gonna be up for thousands of dollars.
in s sometimes hundreds of thousands of dollars in stamp duty and these sort that may actually end up being a better outcome for them overall in the long run than staying in the current structure and copying the thirty percent tax, for example. And like how do you have that conversation with a client? Well to be honest, that's a really good segue into the rollover. So the the government had sort of flagged in the budget when the when this was announced that there would be rollover provisions to help people, help businesses transition away from
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discretionary trusts into fixed trusts or companies. And so we've got a little bit of more detail on that in this in this consultation paper. essentially it's a variation of the small business restructure rollover, but one that has, I guess, fewer conditions, that applies a bit more broadly, not just limited to CGT assets or active assets. but to your point, Stacy, that's federal taxes. And you know, if you've got
Dutyable property, you know, could be real estate. It could even be tenants' fixtures, you know, that can be caught as dutable property in Victoria at least. or if you're in Queensland, then business goodwill is subject to duty. there's a lot of issues and and the state territory revenue officers, they haven't exactly expanded their role over this or they now they might, but there's no indication that they will. I don't think they will. Yeah.
One thing that I saw that was interesting, just one point on that rollover, is something that's been I've had some discussions with people about having companies with multiple share classes, the old dividend access shares or the class A, B, C, D, E, F G. specifically says that so if you're gonna use this l leave aside the new structure setup type situation. But if you're gonna if you're gonna use this, well, it's all proposal, but let's say
You're gonna restructure out of a trust to a company and you wanna use this rollover. There's a sp specific mention to using a company with multiple share classes that permit just discretionary direction of dividends or capital. So there's at least some awareness from Treasury that that's what people may try to do as a result of this.
and I thought that was quite interesting. And they're essentially saying that if you've got one of those companies, the rollover won't be available. Yes. But that doesn't deal with that other situation where it's sort of just to set up a new structure and you actually because people have talked there's been a lot of discussion about that as well, that perhaps okay, let's let's have multiple classes of shares so it's not a trust distribution. So it it's yeah, it's it's interesting. But yeah.
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I suppose the other side of that though is if you were to set up a company with multiple classes, then you do risk your sort of small business concessions in the future. And and I know the government did make a point that small business concessions are still there and you know, they will apply to most businesses. in in practice they don't. they're quite complicated and the thresholds are ridiculously low by twenty twenty six standards. but yeah, just another dimension to the to the structuring discussion. Yeah.
No, d d definitely. And I think most people these days are employed by a small business or they've created their own small business. There are more and more graduates coming out of universities and schools these days that go into starting their own businesses than working for somebody else. So this small business community, if you like, is a growing area.
like a massively growing area and I can see why the government are wanting to make some changes in that area. But these changes I don't think are quite the right changes. They're, you know, I'm I'm hoping that they listen to a lot of feedback that, you know, that they've been seeking and actually, yeah, make make some changes here. But I think some of these changes that need to be made are little band-aid fixes here and there.
It's, you know, start again. I think that's a good that's a good end to to that discussion. in terms of other updates for July, we had a a couple of other things. It wasn't as big as some of the other months and and what's what's come out. but nonetheless there is a still a couple of things that are quite interesting. the first one is the ATO released a decision impact statement on the
Case of SEPL, or SEPL, as I like to call it. and just to take listeners through what that case was about, essentially we had a a business running through a discretionary trust. It was originally mum and dad, and then the the the children came in, they were holding various sort of executive level titles.
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And there was a number of vehicles in the in this trust and and and some of those were used for private use. And that was sort of tried to be dealt with as sort of there's loan accounts and trust distributions and that sort of way of dealing with things. but the commissioner assessed it for for FBT. and after a number of decisions, ultimately in the full federal court, the
Court found for the taxpayer and said that one that that these children actually weren't employees to start with. And even if they were employees, that's not enough. You've still got to have a essentially a nexus or a connection between the provision of those cars and that employment. Now, a lot of times with decision impact statements, including this one, they don't really.
really give anything further. They they sort of state it and then say, okay, well, that was the case there, but you know, we'll still apply the law or it's still complicated. And I think my my read of this one was was that it was sort of another one of those that acknowledge that okay there are those tests to apply, but it's probably not really any meaningful guidance provided from there. I think there was a point that I mean the ACN typical fashion f fashion will say that well
Case is limited to its facts, and you know, so they try and narrow it as as best as they can. But there was an interesting point that was made that to get the the the the outcome in this case was sort of very much dependent on some very specific facts, one of which being that the the three beneficiaries, they were they'd never received wages, I think. They they didn't have employment contracts, they never received salary or wages from the business. So there was no evidence that they were.
employed in that sense or that they'd received employment benefits. so I know that for a lot of private businesses, the owners will often pay themselves a salary. And perhaps there's some good hygiene around that, making sure that their super is being contributed to when they're earning a wage, just as their staff are. and I suspect that if you were doing that and at the same time you had vehicles coming out from a trading trust,
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Then you might find it difficult to put yourself in line with Seppel's case because there is evidence of of employment and wages and that sort of thing. So it was an interesting comment that was in there. What what's your perspective, Stacey, on the you know FBT and you know, owners and yeah, like what's the conversation? I know I've I've I've heard historically what those conversations have been, you know, from some other people. But yeah, what's your what's your experience been? I think FBT's always been a
really hard area to get clients to understand and I wouldn't say take seriously, but put attention on because they're very used to lodging an annual tax return and producing a set of financial statements. They're very used to we've got to lodge, you know, an activity statement monthly or quarterly with the ATO and paying super and wages and things on time.
FBT is one of these things that comes around once a year. It's a separate return. It doesn't fall in the same tax year as everything else. And it's to them like a thorn in their side. And until now, there really hasn't been a lot on FBT type cases. And and the is it also the thought it was FBT is for the, you know, the the the the pub the listed companies and the big
The big the big players. The big boys, if you like. Yeah. Right. And so because of that, it's always been a very hard conversation to have with clients. It doesn't mean that we shy away from it. It doesn't mean that, you know, we don't tell them about it. It doesn't mean that we don't do calculations in relation to it and make suggestions to them on what they should be doing, such as lodging a return or doing an ad back in the accounts or whatever it needs needs to happen. But
This case I think is really interesting and also gives us a little bit more weight and credibility to actually show clients that this is what we've been talking to you about for quite a number of years. We've been doing X, Y, and Z or encouraging you to do X, Y, and Z over the last few years. Now, you know, this is why. This is why. And so it's really important that things are documented.
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arrangements are documented. we can look in a set of financial statements and see that, you've got four motor vehicles. Okay, tell us about those motor vehicles and we can ask them about it. The answer we get sometimes is not necessarily what's actually happening. The answer we get sometimes is not some is sometimes sort of glossed over and not the full story. and then the record keeping in relation to that is some.
times another and a whole nother thing because the business might own the vehicle, but the vehicle might be being driven by the wife who doesn't apparently have anything to do with the business. and may actually be paying for the Reg Joe and the insurance and you know everything petrol themselves. so you don't even see anything go through the books for it. So it's quite easy to miss it, you know, or but yeah, no, the car's in there.
owned by the business. Well, it's on the balance sheet. I wonder who actually paid for, you know, like so you go back through historical records, you know, especially if you've inherited a client, you know, or it's a new client that's come on board and you don't get all the information. So those those conversations are crucial to have and to fully understand and to document. And people's role within the business can change. So this could be the wife of a the a director or the wife of an employee.
But that wife could end up, you know, becoming a beneficiary or becoming a shareholder, becoming a director, or be you know, end up taking up another role within the business as well. And that can then potentially reframe what's going on and what the arrangement is. and clients don't realise that, but it I also can't really expect them to either. It's like a really complicated area. But what we can expect is for them to
Have discussions with us about what is going on. So when we ask about this motor vehicle, tell us the full story so we can actually help you. Yeah, it's hard to otherwise. Yeah. Yeah. It's a real challenge because I see I see it all the time as a as a lawyer that, you know, dealing with a client and you find some motor vehicles in there. And you can often see, like especially if it's a business where there might be in a trade, for example, you know, you've got a couple of uts and vans and and work vehicles, but then there's always
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the Mustang or the luxury SUV or sedan that's in there and you know full well like so then you'll you you sort of start wondering about those vehicles and how they're being used and treated and and sometimes a client can be very unsure and wishy washy about it because I think they often default to using their entity to buy these vehicles, regardless of whether they're work use or not, because there might be GST benefits or or whatnot. and then yeah, they can be quite unclear about how the vehicle's being used or
yeah, i i I do find it challenging when though when those issues come up. One one of the one of the things mentioned in that decision impact statement was around there was a reference to Division 7A. now SEPL was a trust, so Division 7A wasn't relevant. but if it were a tr if it was a company, then as the ATO notes, you would have to if if you're not if FPT's not going to apply.
then perhaps Division Seven A will will apply. And I think in those type of situations where you've got a private company, you know, working out which one applies is actually quite difficult because there's very different consequences. If it's FBT, it's the company. Yes, to your point, Stacey, they may not have even lodged any FBT returns. They haven't really thought about it. If it's Division Seven A, it's the it's the individual. so very different, very different tax profiles and also just different rules around, particularly with vehicles around
you know, statutory methods and things like that. So I think that's quite a difficult one where it is a company, you know, which one is the one that's supposed to apply, FBT or Division 7A. Yeah. And in this future world where we're potentially all shifting to companies because of this 30% mineral tax, it might become more of more of an issue. So you can just see how it's all so intertwined and connected. Yeah. Yep. Yep. In the words of someone I spoke to that they're forcing everyone into companies and then they're gonna they're gonna they're gonna they're gonna get you all then.
but yes. Yeah. That's it. All right. So I guess yeah, the next the next thing to talk about is cases. And we've had two interesting ones. obviously nothing as big as Bendel, thank goodness. but we had another hardship case. you might recall, I think in the last episode we spoke about the case of Prasser, which involved a case of of serious hardship and the taxpayer in that situation was
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successful in the AR ART after being denied hardship relief from the ATO. and somewhat coincidentally we've had a second case called Baron which was heard in July where the taxpayer in that case was partially successful on their on their hardship application. Another win? Another win for a taxpayer. this taxpayer is a 76 year old film producer sought a release of an income tax debt about 129,000 including GIC.
he had a director penalty liability also. so I suppose the the thing with this, I we're not gonna go into every single factor that the that the ART went through, but I suppose the point is that similar to the other case of Prasser, you know, it was a it it was a case of going through, okay, what is this taxpayer's financial capacity? I believe that they were on a pension.
very limited in c disposable income. so what is their actual capacity to deal with with the debt moving forward and whether that's going to cause what's called serious hardship. in my experience, like dealing with the ATO on these sort of hardship applications, for one, they don't typically come to lawyers because if the taxpayers in hardship, they're not paying for a lawyer to but to the few that I've I've been involved in, the it it's very hard. Like you have to show that you're very, very unwell, that, you know
Like severe mental health issues. You've got to be almost terminal to get, you know, a successful one. But these cases kind of illustr illustrate that maybe that's not the that's it's not quite that difficult, that if you can show genuine financial hardship, then you've got a reasonable prospect of of of getting relief. Of course, these hardship applications, they're so specific to the taxpayer. So there's very little precedential value that you can draw from one hardship case to another one.
But it's more about the approach. And I'm not sure that okay, we've we've got two cases now where the taxpayer's been successful. will the ATO change their approach to hardship applications? Maybe, probably not. I think that's the interesting thing, and it looks like I mean, you don't get all the in intricacies of what happened, you know, th back and forward. But I imagine there would have been JIC remission requests, because if a substantial part was JIC, I mean that seems like your starting point, you'd be asking.
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Hey, can can the jig be remitted? And we don't know, but you know, that might have been a better approach for the ATO just to just to remit the jig, because I I'm sure you've seen Stacy that it's very, very hard to get any jig remission through. absolutely. Yes. At the moment, definitely. And I think like we've been talking to
clients, even before it gets to a point that the ATO is sort of knocking on your door or, you know, trying to find out what's going on or even putting GRC on it, right? Is this you've got this debt, you know, it's a week overdue or it's, you know, approaching, you know, we know cash flow's tight, whatever. You know, or you've got a history of not paying. Be open and honest with us about what's going on.
That's where we can actually help you best. Yeah. is often what we're saying to clients. And what we've also seen with the ATO and you know, other other practitioners have been telling me the same thing too, is that at the moment we're finding clients are having a better chance at actually getting GSC remission or getting a payment plan, even, than what we are calling up on their behalf. And it seems to be that.
we sort of brainstorm it with them. And when I say brainstorm, we're not making things up. We're just trying to flesh out with them what's actually going on. Like, is there a marriage breakdown? Is there a death in the family? Is there a, you know, a a mental illness? Is there, you know, what what's actually going on? Like flesh it all out and play it out and explain it. And so we kind of become counselors in some ways. to actually, you know, get them talking about it because they're just trying to, you know,
their head down and just keep going or bury it under the carpet or whatever and hope it'll go away because they're just not in the right frame of mind to be fixing it or thinking about it at the moment. So we've had some really good situations with clients actually where we've been able to have that open discussion and get them to in a position where they can call the ATO themselves and have that discussion. The ATO, from what I'm hearing from other practitioners, is that it seems that the ATO can sense
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the real frustration and the real, you know, what's going on for that person, you know, or you know, the real upset that's going on and is there for they're showing some empathy and are a bit more, you know, willing to work with them to do something. whereas when we call up, we're the middle person. Do you know what I mean? As a practitioner, you know, we know the story, we know what's going on and we know we're fighting for our client. We also understand where the ATO's coming from. They're owed money and they want it. so, you know, but it's
Well, they don't have the money to pay now, or you know, this is going on for them, we just need a bit of extra time or whatever. And so we're the middle person and it doesn't always come across, I don't think. You know, we try our best, but from the ATO's perspective, I think they feel like they've heard too many of these stories. Yeah. hard to distinguish the genuine ones from the ones that are trying it on. But I think you make a good point that I I know that the ATO to to a lay person, the ATO can be a very scary organization to deal with, but
Also, I think it can be very confronting to sort of put your hand up and and admit that look, I I'm having a problem, I can't deal with it. Or if it's arisen off the back of a a difficult circumstance, it can be very hard to sort of admit to it, I guess, until perhaps it gets a bit too overwhelming or out of control. So I think you've made a really good point that, you know, getting on to it early is is the best strategy. Yeah. Yeah. And that's a lot easier said than done. Of course. Yeah. Of course. Well that's
Move on to we've got two state tax cases for this month. one of which is SKG cleaning, which concerns payroll tax. Yeah, yeah. So look, we we've been seeing an enormous amount of activity, compliance activity in the payroll tax space. it has primarily been i in the context of contractors and grouping, but we are now seeing the employment agency provisions rear their ugly head.
And this is a case. This case is an example of that. Now the the facts of this case are pretty not like they're pretty straightforward. I mean, as as the name suggests, SKG Cleaning is in the business of providing contract cleaning services to third party clients, so government offices, schools, you know, businesses, that sort of thing. And obviously to perform its function, it it engages workers, whether they're employees or contractors, to actually go into the site of
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the client and provide the cleaning services. And typically these are done out of hours. Shopping centers also, you know, commercial businesses that require cleaning services. So that it's pretty the facts are pretty straightforward. The question was who's liable for the payroll tax on that? So the real issue is whether SKG is an employment agent. And the reason it matters is because SKG can be assessed for payroll tax in two different ways here. One is
As an employment agent or under the contractor provisions. And the reason that matters is because under the contractor provisions, there's numerous carve-outs. And in fact, SK's position was, well, these are contractors, we're not an employment agent. Now, ultimately, SKG was unsuccessful and they were held to be an employment agent. But the reasoning is actually quite, quite interesting. So I think that the real distinction with an employment agent is that.
You know, if your business is to provide workers to work in and for the business of another of your client, then essentially what you're supplying is the labor. So I'm supplying workers to work in your business. That's the hallmark of an employment agent. Versus you've got me working on a project and I've got to complete that project and I organize my own workers to complete that project. So it's a
There's a distinction there. It's interesting though, because you can think about it another way that y you know, if you're a landlord and you're the one you in your head it's like, well, I'm being provided cleaning services. I'm not I'm not looking for, you know, some a temporary person to work on reception or something. I I in my head I'm just, you know, it's cleaning services. Or there's a previous case called the the trolley one. I it's integrated trolley management. I just need someone to
I need the trolley's back, basically. You work it out however you want. You can use robots if you want or whatever. Just want those things done. but this is very much shows how broad it is. Shows how broad it is. It really does because like if you think about a shopping center, for example, I mean, what's the shopping center's business? It's to basically provide, you know, tenancies to independent businesses so they can trade. And, you know, obviously the shopping center will make money from that.
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But it seems that, you know, cleaning, keeping that shopping center clean is an integral part of that business. So that, you know, if you engage a contractor or you engage a third party business to provide workers to clean your shopping centre or to clean your business, that is so integral to the running of your business that those workers are seen to be working in and for your business. So it's it's really quite interesting. And the outcome
is obviously the SKG is liable for the payroll tax. But but the important thing with the employment agency provisions, there's no carve outs. Unlike the contractor provisions where there's relevant there's numerous exclusions, the employment agency provisions don't have any carve outs or exemptions. So once you're in, that's it. You're liable for the tax. so I think it's a hard one just like in these type of subcontra contractor arrangements. I think it's one of those things where people didn't really think about that much about, you know, who's up for payroll tax and
you know, this and that, but you gotta make sure that it's done at the right level. you have those conversations and yeah, okay, it's a specialist area, it's a bit niche, but go get, you know, be rock solid on who's actually going to be up for it. And then what do the contracts say between, you know, the landlord and the SKG in this example, and then what do they have with, you know, whoever they're subcontracting to, because it's like that all needs to be
Rock solid. Yeah, absolutely. I think the general point, and it's it's just as applicable here, that if you've got a business that relies very heavily on contractors, think very hard about your payroll tax. Don't assume that they're not covered because they're contractors, because contractors can be brought in in two ways, either under the contractor provisions or as employment agents. you'd rather find out about it before the state revenue does. You probably have this conversation with
clients on all the time, Stacey, around like employee versus contractor and the benefits of purported benefits of one over the other. 'cause I have that too, where it said like, should you just use employees instead than than than contractors? Yeah. Yeah. We do we do have these conversations from time to time. the payroll tax side of it is an area that we're always sort of flagging is, you know, a risk. and to, you know, make sure that, you know
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they're being reviewed constantly. but yeah, this this case is a very interesting one and highlights, you know, highlights some of those issues once again. So it's definitely one that, you know, in prepping for today brought to my attention that, you know, this is now another area that we probably should revisit with clients again. It's sort of one of those things that you you revisit often with them. And if, you know, they do come to you to say, hey, we're looking at employing someone.
which way should we go we get involved with. But sometimes they'll just, you know, they go and it's their business, right? They'll just go and employ and whatever they want to do and you sort of find out a bit after the fact. so from time to time we do sort of I guess, campaign if you like, with clients on, you know, this is a special topic for this month or this quarter. Let's, you know, encourage clients to review their situations and come forward to speak to us.
A bit like the F T one. Yeah, exactly. Yeah. To get some help with. And sometimes it's beyond us, you know, and we refer them on to a lawyer to actually have a look at it properly. We don't hold ourselves out to be specialists in in everything, especially in state taxes and duties. Yeah. that's that's a very tricky area and how sometimes that interacts with other laws, especially federal ones.
Yeah, can be different sometimes. It's hard for a number of reasons. I mean, your professional indemnity, insurance, you know the the the tax pract the tax agent services act and it it makes it makes it difficult. always say it's it's fine if you get it right, but if you don't get it right, yeah. It's really bad. Yeah. And every state has different rules around different things as well. So yeah, but yeah, documentation and discussions are probably yeah.
Very important. Yeah. And pay payroll tax is is going to be a special feature for this year because there's the the big Uber case, which is on appeal to the High Court. that hearing occurred in April, I believe. So we're waiting at awaiting a decision, and that decision will have numerous flow on consequences, not just for Uber, but for a lot of industries that work on a somewhat similar model. And that's relevant to the contractor provisions, not really to employment agents. But nonetheless, it is still payroll tax and it's
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Yeah, it's all it's all still very topical for the we've got one other one, which stood out to me 'cause it's got a great name firstly. and then just just to show I guess some of the difficulties and challenges around around transfer duty or stamp duty. This is a New South Wales case. it's called Forever Grateful Holdings and the Chief Commissioner of State Revenue.
so was it heard in the Supreme Court in New South Wales? And this was all to do with a change of trustee in a trust. Wanted to change the trustee. And the the question, I was gonna say the million dollar question, but it was a $250,000 question was is there $250,000 of duty that applies to that or $100? So pretty high stakes on.
A change of trustee. Now, I suspect what's happened here is the land is in Moama, which I think is right on the border with Victoria. And I've seen these before where where you've got properties that are near a state border, you can have an advisor that's not in that jurisdiction that's doing it.
And I suspect this is one of those because I've seen similar. I'm not saying that it is, but I suspect that it might be one of those where there was a change of trustee. And in New South Wales, there's a couple of requirements to avoid duty. One is that you have to restrict the essentially the trustee from becoming a beneficiary, which you don't have to do, let's say in Victoria. So you need the deed to actually say that before you do your change of trustee.
And then the second one is around New South Wales have these very strict provisions around what's a foreign trust. And basically if you don't have very particular terms in the trusted, then you will be up for those surcharges. Now th this was one of those situations and essentially it looks like documentation was essentially prepared, at least on a draft basis, without
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regard to those things. Essentially what looks to have happened is essentially that the those materials were uploaded to the Revenue New South Wales portal in draft form. And essentially with a these is the draft documents, can you confirm that it's exempt for duty? Now what came back is no, it's not exempt for duty because you didn't have this stuff in your trusted. And here's an assessment. Not good so far.
Essentially what the court held was that those documents essentially that were uploaded to start with weren't the final documents and they were draft documents. And that wasn't enough to crystallize the the liability at that point. so sounds interesting, sounds but I guess that shows just how hard some of the state tax stuff is. And you think something as innocent as changing the trustee.
Well, you know, in a dispute, yes, they won in the end, but in a dispute over two hundred and fifty thousand dollars of of liability on on that, it's yeah, it it shows sort of how dangerous some of that some of that can be. I think it's even even remarkable that the Revenue New South Wales attempted to assess the transaction on unsigned documents. Yes. I mean, I would have thought the documents need to be signed before we start issuing assessments.
So yeah, that was interesting too. I think it gives some comfort. Well, as much as you can get comfort that when you do these duty exemption applications, you ask the the the the state revenue office for an exemption. This this does differ state to state, but it may be possible to sort of get the answer on the documents without them being in a in a in a in a finalized form. Although I could imagine the states now turning around and saying,
You gotta make sure you sign those first before we say Yeah. Well, that's certainly what I see in Victoria. Like there you there was a there is a ruling process, but more often than not these days, Victorian revenue will just refuse to rule. but you can bet your bottom dollar if you send them unsigned documents, they'll just send them right back and say, Come talk to us when you've got signed documents. we're not we're not here to guarantee your duty outcome or to give you a heads up. so yeah, I
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I don't really see this issue come up all too often. But Well, I think this taxpayer will be forever grateful. Absolutely. Yeah. It's interesting because like last month we had this other case, Winya, which is a payroll then, you know, they had a win. So we're getting these very aptly named taxpayers coming through the courts, which Yeah. If we have any cases in the month, even if they don't teach us anything, if they've got if they've got fun names, then they'll be included.
So I think then with that, that that pretty much concludes our agenda for this month. So a bit bit light on compared to previous months, obviously with the whole the whole brew haha around the budget and whatnot. we're still getting remnants of that with that 30% tax consultation paper, but certainly not as much this month as as there was previously. Yeah, a few implementation parts. AML starting, payday super. We we're gonna be kicking around this 30% tax for some quite some time, some FBT.
but yeah, I've really enjoyed having you on the show, Stacy. and yeah, your your perspective from a practical perspective and and just you know insights. I think you said it really well about some of the 30% tax stuff and also the FBT that it's just not front of mind. so yeah, I wanted to thank you once again for for being part of this episode. another plug to your Michelle and Stacy podcast as well, if you like to hear that.
Hearing what Stacey has to say, then go go check out the podcast. Thank you. Yeah, no, no problem. and just one final point that if you wanted to hear a little bit more from Rajan and I, we'll have obviously next month's tax talks. But we've also got a private clients summit in in Melbourne on the seventeenth of September 2026. So if anyone in Melbourne or Victoria is interested,
Feel free to reach out and can send you all the details about that. Fantastic. Well, thank you again, Stacey, Andrew, and see you at the next one. Thank you. Thank you. Thanks for having me.
