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Capital management issues: returns and buybacks; hybrid securities; IFRS.

Publication date: 13 Dec 05 | Source: WEEKLY TAX BULLETIN

Issue: No 49 25 November 2005

Pages: pp. 1807-1809

Abstract:
Although a capital return or share buy back will always be driven by commercial considerations, the relevant tax rules are very broadly drafted and force most companies to seek a Tax Office ruling to confirm the tax treatment for their shareholders.

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Author profiles

Paul Abbey
Photo of author, Paul ABBEY Paul is a Partner in the Corporate Tax group of PwC in Melbourne and has over 30 years experience advising local and international clients on income tax issues. - Current at 29 May 2019
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Peter Collins FTI
Peter Collins, FTI, is a Partner at PwC with 25 years experience as a specialist in global tax, assisting foreign investors structuring their Australian investments and Australian corporates expanding offshore. He works with the firm’s global tax network to develop solutions for clients and is a member of the International Tax executive, which allows him to provide a unique global perspective. He is a consultant to Treasury in relation to tax reform in the areas of international tax and transfer pricing, including the MAAL/DPT and a member of the Treasury’s BEPS Tax Advisory Group. Peter was heavily involved in the rewrite of the Australian transfer pricing rules; he appeared before the Senate Estimates Committee to object to the retrospective application of those rules to US companies. He represented PwC before the Senate inquiry in relation to corporate tax avoidance by multinational companies. - Current at 01 November 2018
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Wayne Plummer ATI
Photo of author, Wayne PLUMMER Wayne Plummer is a Tax Partner at PwC with over 30 years of corporate tax experience. He advises a range of multinational companies in relation to their Australian tax affairs. Wayne specialises in the tax consolidation rules, capital management and M&A. - Current at 19 June 2018
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