Thanks for highlighting that from ATO. These are a number of grey areas and I think they are saying "this is something that can be done in a number of ways that may/not be in the spirit of the legislation, so we have to put some thought to it".
It would be fantastic if they could actually give some clarity to these things because there is a lot of vagueness that you don't want clarified for you after the event.
I think this is what is holding many people / product providers back - uncertainty!
