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Treating at call loans as equity presentation


Matters covered in this presentation include:

  • section 45B risks on repayments - ATO approach
  • non-deductible interest
  • frankable return
  • non-share capital accounts
  • impact of material change to terms of loan
  • international taxation considerations.

Author profile:

Gary Christie
Gary Christie is head of Deloitte’s National Tax technical area. Gary provides advice on a wide variety of transactions as well as undertaking the internal tax technical training and quality assurance reviews for Deloitte nationally. Gary is also heavily involved in a range of consultation on new tax measures with both Treasury and the ATO. Prior to joining Deloitte, Gary spent over 25 years in the ATO mainly in the Large Business and International segment, the last few years occupying the role of Assistant Commissioner. He also headed up the National Energy and Resource segment and was critically involved in the management and resolution of large audit cases and disputes. Gary has an excellent working relationship with the ATO and an in-depth understanding of its administrative processes. Current at 12 September 2012 Click here to expand/collapse more articles by Gary CHRISTIE.

This was presented at Credit Loans into Companies: Ignore them at your peril.

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Individual sessions

Treating at call loans as equity

Author(s):  Gary CHRISTIE

Materials from this session:

Treating at call loans as debt

Author(s):  Garry BOURKE

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