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Asset financing/thin capitalisation/infrastructure update paper


There are radically divergent views emerging in relation to the interpretation of control and significant influence particularly in the context of minority shareholdings and shareholder arrangements. The flow-on impact upon provisions including Div 6C, debt/equity rules, interest deductibility, thin capitalisation and Div 250 is a contentious issue. This paper examines those issues and some other related recent developments in the context of project financing and consortium investment structures, in particular:

  • control, negative control, sufficient influence and connected entities in the context of Div 6C, Div 974-80 and thin capitalisation
  • thin capitalisation issues including related party debt rules and the ATO view of 820-39
  • changes to the definition of “limited recourse debt”.

Author profiles

Stephen Ford CTA
Steve Ford, CTA, is a Tax Partner at PwC, specialising in M&A in the infrastructure, PPP and energy sectors. Steve is a member of the IPA Tax Committee. Steve was previously an Executive Director with Macquarie Capital, specialising in project finance and infrastructure. - Current at 26 June 2019
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Arash Azimi
Arash is a Senior Consultant at PwC. - Current at 13 February 2013
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This was presented at 2013 Financial Services Tax Conference .

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Individual sessions

Topical tax treaty issues for the financial sector

Author(s):  Richard J VANN

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Emerging regional issues (funds management)

Author(s):  Daryl CHOO,  Brian CHAMBERS

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Australian Taxation Office audits, risk identification, dispute

Author(s):  Ashley KING,  Andrew MCLOUGHLIN

Materials from this session:

GST and RITCs on trustee services

Author(s):  Amelia O'Rourke,  Bill PACKWOOD

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New R&D regime in financial services

Author(s):  Jamie MUNDY

Materials from this session:

The promoter penalty regime - How the ATO ia applying it in practice

Author(s):  Bruce COLLINS,  Nathan FIRTH

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