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Published on 21 Aug 08
by VICTORIAN DIVISION, THE TAX INSTITUTE
This paper covers:
Fundamentals of Interest Deductibility
what is interest? (BHP Co and the debt/equity provisions)
is it too soon? (Steele's case)
is it too late? (Brown's case)
purpose/use (Macquarie Finance and St George cases)
refinancing (Smith & Roberts case)
derivation of income (Total Holdings and Spassked)
interest withholding tax
how do the Debt/Equity rules impact interest deductibility?
effective non-contingent obligations
limited recourse debt
impact of recent cases including St George.
transfer pricing and interest
guarantee fees and intra-group loans
an examination of the ATO's recent discussion paper.
Michael Jenkins FTIA is a principal at Deloitte with 10 years experience in transfer pricing covering various industry sectors. In recent times Michael has focused on transfer pricing issues relating to the pricing of debt and related issues. Current at 21 August 2008
Neil Ward FTIA leads the Deloitte Australian Financial Services Tax Group. He has more than 30 years
experience in advising in tax. Prior to joining Deloitte in March 2000, Neil spent 12 years with the ANZ
Banking Group in Australia and the United Kingdom. Neil is recognised as one of the leading tax advisers
on financial arrangements, foreign exchange, thin capitalisation, capital management, withholding tax and
infrastructure transactions. Current at 11 March 2009
Helen Fisher FTIA is a partner at Deloitte with over 12 years experience, specialising in providing tax consulting services to Financial Services Industry clients. She advises listed and multinational clients on various aspects of Australian taxation laws, including structured finance transactions, corporate restructures, mergers and acquisitions and international tax matters. Current at 21 August 2008
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
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