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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 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 Click here to expand/collapse more articles by Peter MCCULLOUGH.
 

This was presented at Tax in an Uncertain Economy.

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The perspective of the appointed representative

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