Value shifting: avoiding its perils
Publication date: 01 Mar 07
Source: "TAXATION IN AUSTRALIA" JOURNAL ARTICLE
Abstract:
The general value shifting rules are a regime aimed at dealing with artificial gain and losses that are generated by particular schemes on the realisation of equity or loan interests in an entity. This article provides a brief overview of the exemptions that are available from the value shifting rules that can be utilised to avoid their application.
Author profile:
Dr Philip BenderPhilip Barrister at Law, Victorian Bar has many years experience in advising on international tax, including structuring of managed funds and other inbound and outbound investments. Philip advises and appears regularly for taxpayers and the Commissioner in both the AAT and Federal Court, including on international tax matters. He also appears in commercial and trust matters in State Courts. Philip is also a contributing author to 2 books (Taxation of Financial Arrangements and Business Tax Reform in Prospect and Retrospect) and has published numerous articles on international tax issues.
Current at 26 August 2011
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