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Taxation of hybrid securities


Since October 1998, Australian companies have raised over A$7 billion through the issue of hybrid securities in the form of trust preferred securities and income securities. This is a reflection of the active capital management strategies which have been adopted by some Australian multinational companies, particularly banks, as a means of enhancing shareholder value. The main purpose of this paper is to consider the main taxation consequences of the different types of hybrid securities which have been issued by Australian companies since October 1998. Some observations will also be made about the main focus of the ATO's review.

Author profile

Emanuel Hiou CTA
Emanuel is a partner in Deloitte’s financial services industry tax practice. Emanuel specialises in tax consulting for M&A transactions, corporate restructures, capital raising transactions, cross-border funding structures and tax risk management for the banking industry. Prior to joining Deloitte in March 2010, Emanuel had 14 years experience with National Australia Bank (NAB) in various tax leadership and advisory roles, including Head of Group Taxation for nine years. In those roles, Emanuel contributed to many M&A deals, capital raising transactions and product development initiatives in NAB’s banking and funds management businesses. - Current at 30 September 2011
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