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Thin capitalisation - a selection of issues paper

Published on 19 Sep 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • some aspects of foreign control
  • the role of accounting standards
  • the arm's length debt concept
  • the 'safety' of safe harbour?
  • the relevance of 'association'.

Author profile:

Geoffrey Dunn FTI
GEOFFREY DUNN FTIA graduated from the University of New South Wales in Commerce (Accounting) in 1975. In more recent times Geoffrey has completed the Diploma of Law awarded by the Legal Profession Admission Board of New South Wales, and was admitted earlier this year as a Solicitor of the New South Wales Supreme Court. During the period 1988 to 2000 Geoffrey was a Corporate Tax Partner with PricewaterhouseCoopers, and since 2001 upon retiring from the partnership, has been engaged in a technical advisory role for that Firm as a Technical Director. Prior to joining the predecessor firm of PricewaterhouseCoopers in 1984, Geoffrey held a number of accounting roles in commerce. From 2001 as part of his technical focus at PricewaterhouseCoopers, Geoffrey has specialised in the debt and equity and thin capitalisation rules. Current at 12 December 2007 Click here to expand/collapse more articles by Geoffrey DUNN.
 

This was presented at International Tax Masterclass.

Get a 20% discount when you buy all the items from this event.

Individual sessions

Changes to the foreign tax credit regime - a high level summary

Author(s):  Jeremy HIRSCHHORN

Materials from this session:



Interpretation of double tax agreements

Author(s):  Richard SHADDICK

Materials from this session:




Further details about this event:

 

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