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Developments in cross border financial transactions - ATO perspective paper


This paper covers:

  • importance of the Australian/international tax base
  • overlaps and gaps between jurisdictions
  • features to look out for
  • relevance of Part IVA and debt equity regime
  • interacting with the ATO.

Author profiles

Ashley King CTA
Ashley is a Partner in the Tax Controversy team at PwC. He focusses on strategic resolution of tax disputes. Ashley has over 25 years tax experience including 20 years with the ATO. Ashley was one of the youngest tax officers to have been promoted to assistant commissioner in the ATO in 2001, and was senior assistant commissioner for Large Business and International Tax division when he left the ATO to join PwC in 2007. Ashley recognises that attempting to resolve tax disputes comes with its technical complexities. By combining his extensive ATO experience and his insight into contemporary ADR processes, Ashley has been instrumental in advising many clients in negotiating complex tax dispute settlements. He has also successfully assisted many clients in defending their tax positions, including through obtaining positive ATO rulings. - Current at 29 October 2014
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Paul is a Senior Technical Adviser in the Finance & Investment Centre of Expertise in the Melbourne office of the ATO. Paul has over nine years experience at the Tax Office and has spent most of that time specialising in tax matters relating to financial services. Prior to the legislative function being relocated to Treasury, Paul worked as a member of the Taxation of Financial Arrangements team. His current responsibilities include provision of advice and assisting compliance teams on hybrid finance transactions and a range of banking and finance issues. Paul is a member of the Finance & Investment subcommittee of the National Tax Liaison Group and specialises in the application of the debt/equity provisions.
Current at 12 December 2006


This was presented at 2007 Financial Services Taxation Conference: Financial Services Unleashed .

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

Individual sessions

Infrastructure and property investment - taxpayer's and ATO perspectives

Author(s):  Simon Clark,  Christopher HOOD

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Revenue losses and capital gains

Author(s):  John W DE WIJN

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Retail financial products

Author(s):  Kirsten FISH

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Promoter penalties and financial product providers - a provider's perspective

Author(s):  Glenn HUNTER

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Innovative capital raisings

Author(s):  Vik KHANNA

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Developments in cross border financial transactions - advisor responds

Author(s):  Andrew MILLS

Materials from this session:

Further details about this event:


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