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St George Bank Ltd and the cost of structured capital paper


The St George Bank case raised some fundamental questions about the relationship between capital and income expenditures. This paper covers:

  • "incurred in gaining"
  • "of capital, or of a capital nature"
  • Macquarie finance
  • St George Bank
  • loan capital cases
  • significance of the St George Bank case.


Author profile:

Author Photo - Anthony Slater CTA
Anthony Slater CTA
Tony has practised in revenue law, and has been a member of The Tax Institute and a speaker at its conventions, since the early 1970s. He has grappled with the capital/revenue distinction both before and after the introduction of CGT, and appeared for both taxpayers and the Commissioner in cases where the distinction was in issue. He does not think it has been abolished. Current at 19 March 2015 Click here to expand/collapse more articles by AH (Tony) SLATER.

This was presented at 2010 Financial Services Taxation Conference.

Get a 20% discount when you buy all the items from this event.

Individual sessions

Preference shares and nonshare equity

Author(s):  Monica JORDAN

Materials from this session:

St George Bank case update

Author(s):  Deborah HASTINGS

Materials from this session:

Tax accounting issues affecting the financial services industry

Author(s):  David L WILLIAMS,  Stef MASON

Materials from this session:

Division 230 and equity interests

Author(s):  Euan CAMPBELL

Materials from this session:

Division 974 and limited recourse debt

Author(s):  Euan CAMPBELL

Materials from this session:

Paragraph 177EA(17)(ga)

Author(s):  Peter WALMSLEY

Materials from this session:

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