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Hedging workshop paper


This paper covers the application of the TOFA hedging method to hedging of net investments in foreign operations, exempt dividend income and interest rate hedges through worked examples to illustrate:

  • identification of the appropriate hedged item
  • the contemporaneous documentation required
  • how effectiveness is tested
  • what the different book and tax treatment means for the ineffective portion
  • other differences between book and tax treatment
  • what happens when things change: effectiveness, consolidation and accounting changes.

Author profile:

Julian Humphrey CTA
Julian, CTA, is a Partner of KPMG’s Banking and Finance practice with over 18 years experience. He works primarily with international banks and financial services companies operating in Australia, providing corporate income tax and more recently transfer pricing services. Julian’s areas of expertise include the taxation of banks and bank branches, the taxation of financial arrangements and retail financial products as well as Australia’s offshore banking regime. He has advised on a number of major M&A transactions in the financial services sector in recent years. He is currently heavily involved in the base erosion and profit shifting debate, working with clients to implement country-by-country reporting. He is a regular participant in consultation with the government on Australia’s tax reform proposals affecting Australian financial institutions. Current at 17 March 2016 Click here to expand/collapse more articles by Julian HUMPHREY.

This was presented at Financial Services Taxation Conference 2009.

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