Published on 27 May 09
by VICTORIAN DIVISION, THE TAX INSTITUTE
This paper covers:
- the role of Division 166
- the companies to whom Division 166 applies
- how Division 166 modifies the basic continuity of ownership test
- corporate change
- the tracing concessions
- the stakeholder thresholds of the concessional tracing rules
- the no detriment rule: section 166-275
- interposition of a new entity between notional shareholders.
Martin has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne.
- Current at
30 August 2017
Jeanelle works for Allens Arthur Robinson.
- Current at
15 September 2017