Published on 02 Nov 07
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper covers current issues facing corporates in interpreting the debt equity rules in a cross border context, including:
- what is a non-contingent obligation?
- how do the debt/equity rules interact with the DTAs?
- current issues when issuing or investing in hybrid instruments cross border.
Martin has been a Partner in the Allens Tax Group for 20 years and in that time has been extensively involved in advising resource companies, infrastructure projects, banks and IP intensive businesses. In recent years he has focused on contentious cross border issues, both from a litigation perspective and in alternative dispute resolution.
- Current at
30 November 2020