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Current issues facing corporates in interpreting the debt equity rules in a cross border context paper

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.

Author profile:

Martin FRY
Current at 05 November 2013 Click here to expand/collapse more articles by Martin FRY.
 

 

This was presented at Annual Corporate Tax Intensive: Complex Tax Issues Uncorked .

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Transfer pricing implications of related party funding arrangements

Author(s):  Paul BALKUS

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The current cross border co-operation arrangements between revenue authorities

Author(s):  Jan Farrell

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