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Taxation of Financial Arrangements - scope and exceptions paper

Published on 15 Feb 06 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

This workshop paper covers:

  • is the very wide definition of a 'financial agreement' workable?
  • are the exceptions and carve-outs adequate?
  • alternative approaches?
  • comparison to the financial accounting definition of a 'financial instrument'
  • the New Zealand experience
  • character rules: is the deemed revenue treatment appropriate?

This paper was also presented at the 'Taxation of Financial Arrangements' seminars held in Melbourne on 9 March 2006 and Sydney on 22 March 2006.

Author profile

Anthony Frost CTA
Photo of author, Tony FROST Tony Frost, CTA, Greenwoods & Herbert Smith Freehills’ Managing Director, is a tax lawyer and Chartered Accountant, with a career spanning more than three decades. During this time, he has advised clients on a wide range of matters, including financial transactions, ATO audits and disputes, and the tax aspects of mergers, acquisitions and transfer pricing. Tony has been closely involved in many successful and unsuccessful tax reform projects over the last 30 years or so, including in his role as a key adviser to the Australian Banking Association, and also as an occasional adviser/consultant to the Treasury, ATO and the Board of Taxation. Before joining Greenwoods in 2003, Tony was a partner in a global chartered accounting firm and held a senior position in a leading Australian bank. Tony is a prolific author of tax articles and seminar papers and is regularly invited to speak at industry events and conferences. He spent 15 years as a lecturer in the Master of Laws program at the University of Sydney. Tony is a Chartered Tax Adviser of The Tax Institute, a member of the Law Society of NSW and Chartered Accountants Australia and New Zealand, and a member of the International Fiscal Association. - Current at 01 November 2018
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This was presented at Taxation of Financial Arrangements - Practical Application .

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Individual sessions

Taxation of Financial Arrangements - scope and exceptions

Author(s):  Tony FROST

Materials from this session:

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