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Outbound Thin Capitalisation


This seminar paper is divided into two parts. Part I deals with the general framework of the thin capitalisation legislation, and Part II with the precise formulae and more detailed discussion on how these rules effect outward investors.

Author profile

Prof Robert Deutsch CTA
Bob is Senior Tax Counsel at The Tax Institute. Bob was previously Deputy President of the Administrative Appeals Tribunal (AAT), and for over 20 years he was a Professor in Taxation Law with the University of New South Wales. Bob specialises in taxation matters, with a special emphasis on international tax, and his time with the AAT has required extensive involvement in corporate law, social security and immigration matters. He also has experience as a solicitor with a major national law firm, as an independent barrister, and as a director with a major accounting firm. He has written widely in his fields of specialisation as well as in the area of financial statements, and is an ongoing contributor to the highly successful Thomson Reuters Australian Tax Handbook. He is also a regular conference presenter for a number of organisations, including The Tax Institute and the University of New South Wales. Bob has deep expertise in both tax practice and tax education, developed over many years at the highest levels. - Current at 19 February 2018
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This was presented at Thin Capitalisation Rules .

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Outbound Thin Capitalisation

Author(s):  Robert DEUTSCH

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