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Thin capitalisation including the impact of falling asset values paper


This paper examines:

  • the impact of the changed financial environment on thin capitalisation
  • will the proposed new rules help?
  • are there viable alternatives (eg. arm's length debt test)?
  • is the safe harbour really a safe harbour?

Author profiles

Paul Balkus
Photo of author, Paul BALKUS Paul is the co-leader of Ernst & Young’s Oceania Transfer Pricing practice. He has over 20 years experience in the field of tax and transfer pricing including significant experience in servicing clients across most industries including financial services, mining and resources, pharmaceutical and fast moving consumer goods. Paul has been involved in all aspects of transfer pricing including advance pricing arrangements, dispute resolution, planning and documentation. More specifically, Paul’s experience has included addressing transfer pricing issues in connection with inter-company arrangements involving supply chain restructuring arrangements, global funds management, credit and performance guarantees, global trading and intercompany financing. - Current at 14 July 2017
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Daryl Choo ATI
Daryl is a Partner in the Financial Services Group at Ernst & Young specialising in the taxation of international and domestic funds. Daryl has extensive experience in advising on the structuring of international (inbound and outbound) and domestic funds and advising due diligence committees on transactions including IPOs, acquisitions, restructures and disposals. - Current at 13 February 2013
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This was presented at Financial Services Taxation Conference 2009 .

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Individual sessions

TOFA and hedging

Author(s):  Mathew UMINA

Materials from this session:

Tax issues in a bear market: Assets side

Author(s):  Allan BLAIKIE

Materials from this session:

Financial services tax update

Author(s):  Antoinette ELIAS

Materials from this session:

Managing TOFA, implementation and ongoing–Tax Office perspective

Author(s):  Ross BROOKES

Materials from this session:

Walking the wire-The Australian economy in 2009

Author(s):  Michael BLYTHE

Materials from this session:

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