Published on 26 Nov 03
by VICTORIAN DIVISION, THE TAX INSTITUTE
This presentation addresses the following issues:
- whether the head company needs a funding arrangement - accounting issues and directors' duties
- whether the group needs a Tax Sharing Agreement (TSA) - benefits, directors' duties and relationship to ASIC cross
- issues in drafting Tax Sharing and Tax Funding Agreements - allocation methodology, liabilities covered, entities covered, dealing with losses and record keeping
- pitfalls in the TSA regime
- how you provide third parties with a level of comfort that the TSA will work.
Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne. Current at 12 February 2016
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Grant Cathro CTA
Grant is a Partner with Allens Arthur Robinson, practising extensively in the resources sector.
He advises clients in relation to project structures, acquisitions and divestments, ATO audits and disputes.
Grant has over 25 years experience in both resource rent tax and income tax issues Current at 17 February 2011
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