Miscellaneous 2015

An update on capital management issues

Source: The Tax Specialist Journal Article

Published Date: 1 Aug 2015


Any capital management strategy carries a number of taxation implications which should be carefully considered before implementation of the strategy. This article considers some current key tax issues associated with common and topical capital management strategies, including the tax treatment of returns on certain funding instruments following the Mills case, share buy-backs, including the implications of the decision in the Consolidated Media Holdings case and the status of proposed reforms, debt buy-backs, and certain debt/equity issues.

The article discusses common capital management tax issues for general corporate taxpayers. There are specific tax issues that can arise for authorised deposit-taking institutions, that is, banks and other financial institutions, which are outside the scope of the article. The author concludes with a recommendation that tax teams ensure that time for obtaining advice around the issues (including ATO rulings where appropriate) is factored into the timetable for execution of capital management strategies.

Sorry, this is subscriber only content.

To gain access to this material and much more - Subscribe Now.

(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).

Already a Subscriber? Login now

Already a Subscriber? Login now


The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))


The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.


Miscellaneous 2015

Share this page