Your shopping cart is empty

Dealing with rights and obligations under contractual arrangements–Rescheduling or cancellation paper

Published on 06 Nov 08

This paper covers:

  • 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
  • suspended interest
  • 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).

Author profile

Peter McCullough CTA
Peter is a tax partner at Ashurst. He has over 30 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, financing and mergers and acquisitions. - Current at 25 June 2018
Click here to expand/collapse more articles by Peter MCCULLOUGH.


This was presented at Tax in an Uncertain Economy .

Get a 20% discount when you buy all the items from this event.

Individual sessions

The perspective of the appointed representative

Author(s):  Barry KOGAN

Materials from this session:

Further details about this event:


Copyright Statement
click to expand/collapse