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Division 250 presentation


Division 250 had a difficult birth and is proving to be a troublesome infant. The law is derived from anti-avoidance issues connected with dealing with tax exempt state government entities but it now has an impact on ordinary, commercial real estate transactions. This presentation considers some of the practical difficulties and unresolved issues arising from the application of Division 250, including:

  • the impact of financing multiple properties with single debt facility
  • what is the most appropriate measure of expected financial benefits?
  • how to calculate the value of a building at the end of an arrangement
  • whether it is appropriate to apply Division 250 to foreign property held through a foreign entity
  • the impact of borrowing from an offshore financial institution on the limited recourse debt test.

Author profiles:

Michael COX
Michael is a Director with PricewaterhouseCoopers specialising in the taxation of real estate, with a particular focus on cross-border real estate transactions. Recently, Michael has advised on a number of IPOs for Australian listed property trusts and the acquisition of assets in various jurisdictions including the USA, Japan, Singapore and Germany. Michael previously worked for PricewaterhouseCoopers in South Africa where he advised on a number of inbound and outbound transactions and operating structures.
Current at 27 August 2008 Current at 11 March 2009 Click here to expand/collapse more articles by Michael COX.
Brian Lawrence FTIA is a Partner with PricewaterhouseCoopers. He has specialised in corporate tax for over 20 years and has been involved in many corporate activities including mergers, acquisitions and Initial Public Offerings. Main client responsibilities include property companies, property trusts, property developers, banks, financial institutions and funds management activities. Clients include major Australian corporate groups. Brian has extensive experience advising on real estate tax matters including IPOs for a significant number of listed property trusts and property syndicates, sale and leasebacks and the establishment of numerous funds and stapled structures. He also has extensive experience in performing tax due diligence work on acquisitions.
Current at 27 August 2008 Current at 11 March 2009 Click here to expand/collapse more articles by Brian LAWRENCE.


This was presented at 6th Annual Property Intensive .

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

Individual sessions

Division 250

Author(s):  Brian LAWRENCE,  Michael COX

Materials from this session:

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