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Loans and Financial Arrangements: Principles, Problems and Practical Examples

Published on 16 Feb 2006 | Took place at Pacific International Suites, Perth , WA

Identifying the proper taxation treatment of loans and other types of financial arrangements is one of the most challenging areas of taxation practice. Over the years, this area of law has been the subject of a constant barrage of legislative amendments. In particular, the recent Taxation of Financial Arrangements reforms have resulted in the introduction of a number of revolutionary and highly complex taxation regimes. Keeping abreast of the many developments in this area of law is crucial for all tax practitioners.

These seminar materials aim to provide a comprehensive overview of the key taxation rules that affect loans and other common forms of financial arrangements. They examine the fundamental legal principles relating to these transactions and they focus on the practical operation of the main legislative regimes that operate in this area.

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Individual sessions

General principles relating to the deductibility of interest

Author(s):  Stephen BARKOCZY Over the years, there have been many significant cases that have considered how the general deduction provision deals with interest expenditure. This paper discusses these cases in the context of a series of general propositions.

Materials from this session:

The three Ds: debt equity, debt forgiveness and Division 7A

Author(s):  Len HERTZMAN

This paper:

  • seeks to put each of the 3Ds in context by considering their objective
  • provides a refresher as to the operation of each of these statutory regimes
  • examines aspects of the practical application of each of the 3Ds.
Materials from this session:

Loans and financial arrangements - international issues

Author(s):  Duncan R C BAXTER This paper describes some of the tax issues that arise in relation to cross-border financing arrangements.

Materials from this session: