Published on 09 Sep 08
This paper focuses on complex issues that practitioners face in advising Australian holding companies with foreign subsidiaries. Issues covered include:
- thin capitalisation
- foreign hybrids
- tax incentives for multinational groups
- availability of foreign tax credits
- recent ATO developments affecting Australian holding companies with foreign subsidiaries.
Liam Collins CTA
Liam is a Partner at PricewaterhouseCoopers. He has over eight years experience in advising clients on Australian and international taxation matters. Liam has considerable experience in advising on cross border transactions and major financing transactions. Current at 09 September 2008
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Dr Braedon Clark CTA
Dr Braedon Clark, CTA, has been the Tax Manager of Global Strategy and Compliance EMEA/ASIA at Orica Limited since 2010. Before taking on this role Braedon was a Director in the International Tax and Transaction Services group of PwC, Melbourne. Braedon has over 10 years of experience in the provision of legal and tax advice for cross-border financing and international M&A and is a specialist in international tax, international hybrid structuring and large-scale M&A transactions. Braedon has also worked in tax for Minter Ellison Lawyers and as a Barrister. Current at 24 November 2014
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