John W DE WIJN
This seminar papers discusses interest deductibility, with a focus on the following issues: What is debt as opposed to equity – the traditional approach; The critical tests in determining deductibility of interest; When does interest start and cease to be deductible?; Issues arising on intra group lending; The importance of purpose – do we need to now look at the advisor's role?
This seminar paper discusses thin capitalisation with a focus on: A point-by-point plan to understanding the new rules; The eight categories; The formula for each of the eight categories; Key concepts: understanding and problems; Conclusions: going forward – dealing effectively with the detailed application of the rules.
This powerpoint presentation is an overview themes discusses by the Part IVA discusion panel at the 9th Annual Tax Intensive. Topics covered include: Part IVA in court cases; protection for taxpayers and advisers; and applying part IVA to tax effective investments.
Also included in this download is the reading material distributed for this session.