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Thin capitalisation : a critical review.

Publication date: 01 Jun 91 | Source: "AUSTRALIAN TAX FORUM" JOURNAL ARTICLE

Issue: Vol 8 No 2 1991

Pages: pp.181-216


The object of this paper is to:

- explore the various policy alternatives that were available to the Government in setting a policy aimed at eliminating the perceived inequities attributable to thin capitalisation (including a summary of policy adopted by other countries);

- review of the application of Div. 16F of the ITAA 1936;

- demonstrate that in enacting Div. 16F the Government did not adopt the optimum policy - being a fair, equitable and easily administered policy that eliminated perceived tax minimisation practices, but did not deter investment in Australia.

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Author profile

Sue Williamson CTA-Life
Sue is a partner at EY specialising in tax controversy. Sue has worked in tax for more than 25 years, including roles in major law firms and executive roles within the firms in which she has been a partner. Sue was the President of The Tax Institute in 2008, has been a member of several advisory boards, has participated in many consultative forums and lectures in the University of Melbourne Masters of Law program. Sue was a member of the instructing solicitor team working on the Placer Dome litigation. - Current at 26 June 2019
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