Published on 03 Apr 01
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper dicusses Debt versus Equity, with a focus on the the concept of debt and equity as defined in Division 153 looking at three main areas:
(i) denying deductions for payments in respect of 'non-share' equity and enabling deductibility of payments made in respect of 'debt-like' equity;
(ii) determining equity for the purposes of franking; and
(iii) determining treatment of return of capital;
determining debt capital and equity interests for the purposes of the thin capitalisation provisions.
Paul is a senior director of Greenwoods & Freehills Pty Ltd and has extensive experience in property and, in particular, the structuring of infrastructure projects.
Current at 14 September 2007
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