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Thin Capitalisation and Debt/Equity Rules

Published on 03 May 01 by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE

This powerpoint presentation addresses the following topics: What are the new definitions of debt/equity?; When will interest be deductible? When will distributions be treated as dividends?; Planning points in review of funding arrangements; A practical worked example.

Author profile:

David GRECIAN
David joined Deloitte after 35 years working at the ATO. He has been involved with transfer pricing case work, litigation, public rulings, compliance strategy and policy both domestically and at the OECD for more than 20 years. He also has extensive experience in the Financial Services sector. David is one of the most experienced and influential people in the transfer pricing area and is recognised globally given his position at the OECD for the past six years where he was involved in the development and interpretation of the transfer pricing provisions. David has extensive experience in the financial services industry with both a local and global/OECD perspective, including policy, interpretation and compliance matters. His experience specifically includes public rulings, APAs, transfer pricing audits and litigation of various issues in the financial services sector. He also has particular experience with domestic legislation including Div 820 and Part IIIB.
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Thin Capitalisation and Debt/Equity Rules

Author(s):  David GRECIAN

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