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Taxation impacts of capital management paper


This paper covers:

  • the ATO's position
  • application of section 45B
  • alternatives:
    • special dividend
    • capital return/reduction
    • on-market buy-back
    • off-market buy-back
    • demergers (including stapling)
    • when interest deductions will be allowed.
This paper was also presented at the Capital Management Strategies seminar held in Perth on 9 March 2006.

Author profiles

Mark Ferrier CTA
Mark is a Director at the Sydney office of Greenwoods & Freehills. His expertise covers all areas of taxation, in particular providing advice on taxation law (capital gains tax, international taxation issues and GST) as it applies to corporations. Mark's extensive experience includes providing advice on the taxation affairs of banks, international taxation issues, restructuring of international and domestic corporate groups, mergers and acquisitions, leveraged and cross-border leasing, and other tax-based financial transactions. - Current at 12 January 2017
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Tim Kyle CTA
Photo of author, Tim KYLE Tim is a Director of Greenwoods & Herbert Smith Freehills, based in the Sydney office. He focuses on the resources and financial services industries, advising clients on a wide range of income tax matters, including mergers and acquisitions, capital management, cross-border dealings, market value issues, audits and tax litigation. Tim has worked on a range of matters involving Part IVA advice, rulings and disputes. - Current at 22 June 2017
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This was presented at Corporate Tax Intensive - Tough Tax Topics .

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