Skip to main content
shopping_cart

Your shopping cart is empty

MRRT and Carbon Tax: Issues for financiers and funds presentation

Published on 13 Feb 13 by NATIONAL DIVISION, THE TAX INSTITUTE

The MRRT will have a significant impact on pricing of projects and security positions. Financiers and funds will need to be aware of:??

  • Core mining project interest identification provisions, particularly in the case of joint venture arrangements, passive JV investors, farm-in arrangements andofftake arrangements
  • Concessions that certain miners may claim that have the impact of eliminating allstarting base value and MRRT deductions, impacting on value for funding and security enforcement
  • Transfer of MRRT loss provisions and impact on project valuation
  • Treatment of expenses, in particular, financing expenses, lease expenditure, hire purchase fees, hedging expenses and security deposits
  • Ensuring tax sharing agreements are appropriately updated to remove the risk of joint and several liability for tax liability across entities within a MRRT consolidated group
  • Issues for financing M&A activity.

Financiers and funds will also need to consider the impact of carbon pricing on projects and investment, particularly:

  • Identifying entities that will be required to surrender emissions units in respect of emitting activity, including through operator and control provisions
  • Understanding liability criteria and impacts of failure to comply
  • Understanding carbon price path
  • Anticipating development of derivatives following the fixed price period.

Author profile:

Author Photo - Teresa Dyson CTA
Teresa Dyson CTA
Teresa is a Consultant at McCullough Robertson with over twenty years’ advising clients on infrastructure, financing, corporate tax issues, M&A activity and tax controversy matters. Teresa is actively involved in the legal and tax professions and is the former Chair of the Board of Taxation and Chairman of the Business Law Section of the Law Council of Australia. Current at 18 August 2016 Click here to expand/collapse more articles by Teresa DYSON.
 

This was presented at 2013 Financial Services Tax Conference.

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

Individual sessions

Topical tax treaty issues for the financial sector

Author(s):  Richard J VANN

Materials from this session:



Emerging regional issues (funds management)

Author(s):  Daryl CHOO,  Brian CHAMBERS

Materials from this session:


Australian Taxation Office audits, risk identification, dispute

Author(s):  Ashley KING,  Andrew MCLOUGHLIN

Materials from this session:

GST and RITCs on trustee services

Author(s):  Amelia O'Rourke,  Bill PACKWOOD

Materials from this session:




New R&D regime in financial services

Author(s):  Jamie MUNDY

Materials from this session:

The promoter penalty regime - How the ATO ia applying it in practice

Author(s):  Bruce COLLINS,  Nathan FIRTH

Materials from this session:





Further details about this event:

 

Copyright Statement