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Tax cases: deductibility of payments": guarantee an advantage of a capital kind


The basic question is whether the outgoing is one that relates to This article examines the business structure, when it will ordinarily be capital, or whether it relates to the business operation, when it will ordinarily be revenue, as illustrated in the Bell and Moir case.

Author profiles

Annamaria Carey
Annamaria is a Senior Tax Writer with ATP. She has 20 years experience in tax, spanning publishing, the ATO, commerce and the tax profession. Annamaria has been involved in formal liaison with the ATO and Treasury on a number of Committees including the Consolidation Joint Design Team. She has recently published a textbook on 'Consolidations - The Adviser's Guide' and has addressed a number of forums on consolidations. - Current at 18 May 2004
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Christopher Colley CTA
Chris, CTA, is a Director at Greenwoods & Herbert Smith Freehills. Chris advises corporate and government clients on real estate investments and trusts, as well as share buybacks and international financial transactions. He has wide experience in mergers and acquisitions, cross-border leasing, international bond issues, securitisation, real estate development, structured investment products and GST matters. He is a member of an Australian Taxation Office working group helping to implement new Taxation of Financial Arrangements provisions and also lectures at the University of Sydney. - Current at 17 March 2016
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