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Growing businesses are faced with a multitude of ways of funding expansion. Often the taxation implications will determine which funding structure is to preferred. The matters covered in this paper include:
Interest deductibility - when is interest not interest
Tax timing advantages (sections 8-1, 25-85 and 82KK)
The debt/equity rules and their impact on deductibility of funding costs
Capital injections and value shifting
Financing distributions to owners
Geoffrey was admitted this year as a Solicitor of the NSW Supreme Court. From 1988 to 2000 Geoffrey was a Corporate Tax Partner with PricewaterhouseCoopers (PwC), and since 2001 has been engaged in a technical advisory role for that firm as a Technical Director. As part of his technical focus at PwC, Geoffrey has specialised in the debt and equity and thin capitalisation rules. Current at 23 July 2007
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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