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The fundamentals of interest deductibility paper

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
    • thin capitalisation.
  • Debt/equity
    • how do the Debt/Equity rules impact interest deductibility?
    • key issues
      • effective non-contingent obligations
      • timing
      • related schemes
      • limited recourse debt
      • convertible notes/hybrids
    • impact of recent cases including St George.
  • Debt pricing
    • transfer pricing and interest
    • guarantee fees and intra-group loans
    • an examination of the ATO's recent discussion paper.

Author profiles:

Michael JENKINS
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 Current at 16 September 2008 Click here to expand/collapse more articles by Michael JENKINS.
 
Neil WARD
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 Current at 06 April 2009 Click here to expand/collapse more articles by Neil WARD.

Helen FISHER
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 Current at 16 September 2008 Click here to expand/collapse more articles by Helen FISHER.

Natalie WELLARD
Natalie is an Analyst, National Tax at Deloitte.
Current at 21 August 2008 Current at 16 September 2008 Click here to expand/collapse more articles by Natalie WELLARD.

 

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