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James Millar
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It all comes down to your statement and when that decision was made.(and when you can prove it was made)….

“I decided it was best to pay myself quarterly for cash flow purposes from 1 Jan 2020. First pay was due to be paid on 31 March 2020 for the period 1 Jan – 31 Mar 2020.”

It seems that your first actions to support this were on or around end of March 2020 (if you have evidence the decision was made earlier than March 2020 then you should be fine). Being that 31 March was after the announcements for some of these stimulus measures, a cynic (or ATO) could argue that your decision was motivated in part to get access to stimulus concessions. The test is whether you took a wage with the sole or dominant purpose of getting access to the stimulus measures. If you have a valid commercial reason that could be put forward for first taking a wage at this time then you could prevail in a dispute.

If the ATO decide in a few years to audit taxpayers that took wages for first time in this last half of year they are going to be very busy. There will be tens of thousands taking wages for first time in last six months of this financial year.

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