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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
Geoffrey was admitted this year as a Solicitor of the NSW Supreme Court. From 1988 to 2000 Geoffrey was a Corporate Tax Partner with PricewaterhouseCoopers (PwC), and since 2001 has been engaged in a technical advisory role for that firm as a Technical Director. As part of his technical focus at PwC, Geoffrey has specialised in the debt and equity and thin capitalisation rules.
Current at 23 July 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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