Published on 11 Aug 2003
| Took place at The Menzies Hotel, Sydney
This seminar provided a detailed insight into the proposed new tax regime (Division 250) for asset financing involving tax preferred entities and non-residents.
New Infrastructure/Asset Financing Rules
Author(s): David ANDERSON, Jock MCCORMACK This seminar paper covers the following topics:
- replacement of Section 51AD and Division 16D
- focus on economic risk transfer ('predominant economic interest') rather than control tests
- potential denial/reduction of certain capital allowance deductions
- notional reconstruction of arrangements with financial benefits broken into principal and interest components
- exposure draft legislation (Division 250) and explanatory material released on 26 June 2003 for technical comment
- proposed introduction into Parliament during spring sittings, 2003.