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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 FTI
Martin has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne. Current at 12 February 2016 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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