Published on 11 Aug 03
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This seminar paper covers the following topics:
- replacement of Section 51AD and Division 16D
- focus on economic risk transfer ('predominant economic interest') rather than control tests
- potential denial/reduction of certain capital allowance deductions
- notional reconstruction of arrangements with financial benefits broken into principal and interest components
- exposure draft legislation (Division 250) and explanatory material released on 26 June 2003 for technical comment
- proposed introduction into Parliament during spring sittings, 2003.
David is a Senior Associate at Corrs Chambers Westgarth Lawyers. David has over eight years' experience servicing the taxation advisory needs of major multinational clients, including specific services in relation to major infrastructure, property development, financing and construction projects.
Current at October 2005
Jock McCormack, DLA Piper, is a leading Sydney-based international taxation lawyer with specific expertise in income tax and more than 30 years experience managing complex tax matters. Jock's major areas of expertise include debt and equity structuring, acquisitions/mergers/divestments, international tax including transfer pricing, capital gains tax and major projects taxation issues. Jock also advises various major corporations on ATO tax audits, tax strategy reviews, litigation and related issues including managing, negotiating and settling challenging and contentious tax issues and reviews.
- Current at
24 November 2014