Published on 12 Oct 07
by VICTORIAN DIVISION, THE TAX INSTITUTE
Better understand issues of vital importance for structuring asset acquisitions and project financing for medium to large enterprises and tax exempt and non-resident entities. This paper covers:
- an outline of new Division 250
- how it works
- what transactions are covered? what’s in and what’s out? exclusions
- demonstrating predominant economic interest
- calculation of notional interest income
- a worked example applying the new provisions
- transitional provisions and the repeal of Section 51AD and Division 16D.
This paper was also presented at 'Division 250: Impact for Property and Infrastructure Projects' held in Sydney on 16 October 2007 and at 'Infrastructure - the new opportunities and the new pitfalls' held in Melbourne on 17 October 2007.
Steve, CTA, is a Tax Partner at PwC, specialising in mergers and acquisitions and deals in the infrastructure, PPP and energy sectors. Steve is a member of the IPA Tax Committee and a member of the Expert Panel assisting the Board of Taxation Working Group in relation to debt and equity tax rules.
- Current at
17 March 2016