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.
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 28 July 2006
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David is an International Tax Partner at Deloitte. David has over 20 years experience in
corporate and international tax, including as a partner with Big 4 firms and a leading law firm. He has spent a number of years working in Malaysia and Singapore. David is a member of the ICAA International Tax Committee, has been a member of ATO / Treasury consultation committees and has appeared before Senate Committees on international tax matters. His experience includes a wide range of inbound and outbound structures with a focus on CGT, double tax agreements and foreign hybrids. His work has also included domestic and international tax issues associated with private equity and venture capital.
Current at 18 September 2008 Current at 27 April 2009
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Current at 10 November 2014