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The future of hybrid financing in Australia presentation

Published on 09 Oct 14 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • Australia’s tax hybrid financing history
  • 23AJ evolution
  • debt equity rules and thin capitalisation
  • Division 768-A
  • overview of key changes
  • the “targeted scenario”
  • BEPS action 2: hybrid mismatch arrangements
  • BEPS impact on current hybrid financing approaches
  • observations on future of hybrid financing.

Author profiles:

Joanne LUGG

Click here to expand/collapse more articles by Joanne LUGG.
 
David Watkins CTA
David is the Leader of the Deloitte National Tax technical and policy group. In that role and previously, David has been a member of various consultation groups working with Treasury and the ATO on a range of international tax matters. David has worked overseas for a number of years, variously in Malaysia, Singapore and most recently, in New York where he was principally focused on US outbound investment into Australia, by US corporates, US managed hedge funds and private equity funds. Current at 02 June 2015 Click here to expand/collapse more articles by David WATKINS.

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 08 July 2014 Click here to expand/collapse more articles by Mark HADASSIN.

Craig Church
Craig is a Principal in the Tax Insights & Policy area at Deloitte in Sydney. Craig has almost 20 years experience advising clients on corporate and international tax matters including cross-border financing and acquisitions, tax consolidation and thin capitalisation matters. In his previous role at EY, Craig also spent 9 months working on the Australian Tax Desk in New York. Current at 02 June 2015

This was presented at International Masterclass.

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