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Securitisation vehicles and limited recourse debt amendments paper


Draft Taxation Determination TD 2012/D11 and the proposed amendments to Div 243 have the potential to adversely impact on project financing and securitisation activities.

This paper covers:

  • Securitisation structures:
    • what is s 820-39 aimed at
    • what are the ATO’s views?
    • is this just an issue for securitisation structures used in PPPs?
  • Limited recourse debt amendments:
    • what is limited recourse debt?
    • when do the provisions apply (refinancing, sale)?
    • can the provisions apply even if the debt is ultimately repaid in full?
    • how to calculate the “excessive deductions”, including examples.

Author profiles

Mark Hadassin CTA
Mark is a partner in the Deloitte International Tax Group in Australia specialising in international tax and infrastructure investment. Mark has over 20 years experience providing advice to major Australian and foreign corporates on domestic and international tax issues. Prior to joining Deloitte in January 2010, Mark spent 2 ½ years as Global Head of Tax at the Babcock & Brown group where he had responsibility for all the group's tax matters. - Current at 08 July 2014
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Greig Hubbard ATI
Greig is a Partner in Deloitte’s Business Tax Services practice with 18 years professional experience in providing taxation and legal advisory services. Greig has worked in Australia, the UK and South Africa managing tax functions for and providing tailored tax advice to clients, predominantly in the financial services, infrastructure and agribusiness sectors. Greig has advised clients on structuring and financing of large Australian infrastructure and capital projects and M&A transactions, including both inbound and outbound investments. - Current at 15 November 2019


This was presented at NSW 6th Annual Tax Forum .

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