This seminar paper focuses on a review of the new definitions of 'debt' and 'equity'; an analysis of when a 'contingent' obligation to make a payment will be regarded as a deemed dividend; a review of the tax implications of non arms length shareholder loans; a critique of the tax consequences for payers and payees under the new rules.
Con Tragakis FTI
Con is a Partner in Charge of KPMG’s Tax and Business Services Practice specialising in tax consolidations,
tax dispute resolution and international tax. He advises large and small business on specialist tax-related matters. He
has advised on numerous international structuring projects for small, medium and large business. His particular areas of
business focus are property, infrastructure and financial services. Current at 18 January 2011
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