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Certainty in the current tax funding market presentation


This presentation covers:

  • using the ROT
  • GE case - guarantee fees
  • credit ratings
  • Westpac v CIR
  • what can we learn from these foreign cases?
  • intra-group inbound funding.

Author profile

Dr Braedon Clark CTA
Dr Braedon Clark, CTA, has been the Tax Manager of Global Strategy and Compliance EMEA/ASIA at Orica Limited since 2010. Before taking on this role Braedon was a Director in the International Tax and Transaction Services group of PwC, Melbourne. Braedon has over 10 years of experience in the provision of legal and tax advice for cross-border financing and international M&A and is a specialist in international tax, international hybrid structuring and large-scale M&A transactions. Braedon has also worked in tax for Minter Ellison Lawyers and as a Barrister. - Current at 24 November 2014
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This was presented at Challenges to Funding Structures: Are you at risk? .

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Individual sessions

Certainty in the current tax funding market

Author(s):  Braedon CLARK

Materials from this session:

The Commissioner’s transfer pricing powers and thin capitalisation safe harbours

Author(s):  Toby KNIGHT

Materials from this session:

Practical implications and observations from a transfer pricing perspective

Author(s):  Garrick ROBINSON,  Chris THOMAS

Materials from this session:

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