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Thin Capitalisation and Cross Border Financing - Changes Enacted

Published on 26 Nov 2014 | Took place at Oaks on Collins, Melbourne, VIC

The recently enacted changes to thin capitalisation, foreign dividends and the foreign residents CGT regime are part of the Government’s ongoing response to Base Erosion and Profit Shifting by multinationals. This event went through the new law, examined strategies responding to the new rules including the implications of de-gearing the Australian operations and considered the likely practical implications.

Get a 20% discount when you buy all the items from this event.

Individual sessions

Thin capitalisation and foreign resident CGT changes

Author(s):  Peter Janetzki

This presentation covers:

  • overview & context
  • thin capitalisation reforms
  • non resident CGT integrity measures.
Materials from this session:

Worldwide gearing test

Author(s):  Claudio Cimetta

This presentation covers:

  • WWG concept
  • WWG – new legislation
  • outbound WWG
  • inbound WWG.
Materials from this session:

Australia's new participation exemption (768-A)

Author(s):  Peter COLLINS

This presentation covers:

  • why change the rule in the shadow of BEPS?
  • new Subdivision 768-A and contrast with old section 23AJ
  • what now works and what doesn't
  • Part IVA considerations.
Materials from this session: