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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 CTA
Michael Jenkins, CTA, currently holds the position in the Australian Taxation Office (ATO) of Assistant Commissioner in the Public Groups & International business line. Mr Jenkins has more than 18 years specialist experience in transfer pricing and related areas of international tax. Mr Jenkins was heavily involved in the development of Australia’s revised transfer pricing legislation (enacted 2013), and subsequently led the ATO team preparing ATO interpretative and other guidance materials relevant to the legislation. In his current role, Mr Jenkins is the ATO’s Chief Economist leading a team of around 70 professional economists. Mr Jenkins has been an Australian delegate to the OECD’s Working Party 6 on transfer pricing matters since 2010, and was also Australian competent authority for transfer pricing matters from 2010-2012. - Current at 03 August 2017
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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 06 May 2009
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Helen Fisher
Helen is a partner at Deloitte with over 14 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 law, including structured finance transactions, hybrid instruments, foreign hybrids, TOFA, structuring of global investment funds, corporate restructures, and international tax matters. - Current at 04 November 2010
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Natalie Wellard
Natalie is an Analyst, National Tax at Deloitte. - Current at 21 August 2008
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