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Hybrid financial instruments: Classifying hybrid instruments under the debt/equity rules and related issues paper


This paper covers:

  • debt/equity in context
  • debt/equity outline
  • ENCO and options to convert to equity
  • equity credit features and ratings agency requirements
  • presentation in accounts
  • are returns deductible or frankable?
  • withholding tax implications
  • rollover relief on conversion.

Author profiles:

Author Photo - Cameron Rider FTI
Cameron Rider FTI
Cameron is a Partner at PwC, practising in tax controversy and corporate tax. He was a Professor of Taxation Law at the Melbourne University Law School, and still teaches a course on Mineral and Petroleum Tax. Current at 12 February 2016 Click here to expand/collapse more articles by Cameron RIDER.
Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne. Current at 12 February 2016 Click here to expand/collapse more articles by Martin FRY.

This was presented at 48th Victorian State Convention.

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