Published on 16 May 13
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
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.
Mark is a Partner in the International Tax & Transaction Services Group in the Sydney office of PricewaterhouseCoopers. Mark has over 12 years experience in corporate and international taxation and has also worked in the United States. Mark specialises in international tax and regularly advises clients on taxation issues arising from M&A transactions, cross-border financing arrangements and corporate restructures.
Current at 23 August 2006 Current at 25 June 2013
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Current at 12 June 2013