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The future of hybrid financing in Australia presentation


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

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
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Joanne LUGG
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David Watkins CTA
David Watkins, CTA is the leader of the Deloitte Australia Tax Insights & Policy group. David has over 25 years’ experience and has worked in Malaysia, Singapore and New York. In his current role, David’s focus is on emerging tax developments and in particular, the Australian tax reform debate and the international process addressing Base Erosion & Profit Shifting (BEPS). The Tax Insights & Policy group is involved at various stages in these emerging issues including consultation and submissions, publications and presentations and assessing the impacts of tax law changes. - Current at 21 October 2016
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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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