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"Securitisation": behind the buzz-word


This article discusses the mechanics of securitisaton, and shows that some of the tax issues created by financial engineers are not easily resolved. Issues include: are SPVs financial institutions; interest offset accounts; transfer pricing; withholding tax; deductibility of establishment costs; management fees; and accruals code.

Author profiles

Russell GARVEY
Russell is Director of Tax Consulting with Horwath (WA). He has 25 years experience in commerce and the public and private sectors including 22 years in the taxation field, advising a wide range of clients on State, Federal and International revenue law. Russell has a unique public and private sector experience. As a former Tax Counsel with the ATO, Russell was deeply involved with the development and application of taxation policy and legislation in both Perth and Canberra and penned several public rulings during that time. He provides specialist advice to a wide range of clients in the not for profit sector, including sporting bodies, not for profit hospitals, some of the country's most prominent charities and public benevolent institutions. Russell has also consulted to our public and private universities on all areas of taxation compliance and planning.
Current at 8 July 2004 - Current at 19 November 2004
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Anthony Long CTA
Tony Long FTIA was recently given responsibility for Property and Government/Not for Profit issues within the Risk and Strategy area of the Australian Tax Office. His history within the Tax Office GST area has been largely in relation to Financial Supplies. Prior to that he worked in the Tax Counsel Network and in a range of advisory positions. - Current at 25 August 2014


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