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Sharp edges in a modular world paper

Published on 18 Sep 08

This paper covers:

  • financing deductions - an update
  • debt equity issues in the context of cross border financing
  • effectively non-contingent obligations: TR 2008/3 - the last word?
  • Section 974-80 - where to now?
  • Australia's transfer pricing regime - interaction between our treaties and Division 13
  • transfer pricing and thin capitalisation - is there a safety in safe harbours? TD 2008/20, TD 2007/D20 and ATO Discussion Paper 08/7290
  • the relevance of foreign law consequences to the domestic law.

Author profile:

Ian Stanley FTIA holds Bachelor degrees in Economics and Law from the ANU and a Masters of Laws from the University of Sydney. Ian practises as a Barrister in Sydney specialising in income tax and related revenue matters. He has published several papers on the debt equity regime and lectures in the Masters programme at the University of Sydney on the Taxation of Financial Arrangements
Current at 18 September 2008 Current at 18 November 2008 Click here to expand/collapse more articles by Ian STANLEY.


This was presented at International Tax Masterclass .

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Sharp edges in a modular world

Author(s):  Ian STANLEY

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