Your shopping cart is empty

Securitisation vehicles and limited recourse debt amendments presentation


Draft Taxation Determination TD 2012/D11 and the proposed amendments to Div 243 have the potential to adversely impact on project financing and securitisation activities.

This presentation covers:

  • Securitisation structures??:
    • what is s 820-39 aimed at???
    • what are the ATO’s views?
    • ??is this just an issue for securitisation structures used in PPPs?
  • Limited recourse debt amendments??:
    • what is limited recourse debt?
    • ??when do the provisions apply? (refinancing, sale)??
    • can the provisions apply even if the debt is ultimately repaid in full???
    • how to calculate the “excessive deductions”, including examples.

Author profiles

Mark Hadassin CTA
Mark is a partner in the Deloitte International Tax Group in Australia specialising in international tax and infrastructure investment. Mark has over 20 years experience providing advice to major Australian and foreign corporates on domestic and international tax issues. Prior to joining Deloitte in January 2010, Mark spent 2 ½ years as Global Head of Tax at the Babcock & Brown group where he had responsibility for all the group's tax matters. - Current at 30 May 2017
Click here to expand/collapse more articles by Mark HADASSIN.
Greig Hubbard
Greig is an Account Director in the Deloitte Brisbane tax practice with 15 years professional experience in providing taxation and legal advisory services, specialising in financial services, property and agribusiness tax matters. Greig has advised on various tax issues relating to the structuring, financing and operation of a number of Australian infrastructure and agribusiness transactions. This includes advising both resident and non-resident investors on the tax aspects relevant to agricultural assets and operations, and the application of the specific tax provisions for primary producers. Greig is also a member of the Tax Institute of Australia and a member of the Taxation Taskforce of the Infrastructure Partnerships Australia. - Current at 23 January 2017


This was presented at NSW 6th Annual Tax Forum .

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

Individual sessions

The evolving compliance obligation

Author(s):  Judy MORRIS,  David DRUMMOND

Materials from this session:

Alternative dispute resolution

Author(s):  Deborah HASTINGS,  Gina LAZANAS,  Judy SULLIVAN

Materials from this session:

Franking dividends - Some tips and traps

Author(s):  Brent MURPHY

Materials from this session:

Financial services reforms and regulations

Author(s):  Nidal DANOUN

Materials from this session:

The promoter penalties regime

Author(s):  Aislinn WALWYN,  George MONTANEZ

Materials from this session:

Further details about this event:


Copyright Statement
click to expand/collapse