payments received to induce the rescheduling or cancellation
payments made to induce the rescheduling or cancellation
impact on characterisation for debt/equity purposes
deferral of cash payment - Div 16E and new TOFA rules
cross border issues (does IWT or RWT apply?)
compounding of interest
payments under guarantees
ordinary income and CGT rules for recipient
possible application of the commercial debt forgiveness and other specific anti-avoidance rules
closing or selling the business and continuing to pay outgoings (Brown, Jones, Guest).
Peter McCullough CTA
Peter is a partner at Ashurst and the global
co-head of Ashurst’s tax practice. He has over 26 years of
experience advising on income tax matters, working in accounting
and legal firms. Peter has had a particular focus on international tax,
managing cross-border investments, group reorganisations and
mergers and acquisitions. Current at 01 October 2014
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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