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Thin capitalisation: is debt a dirty word presentation


Topics covered in this presentation include:

  • why are thin capitalisation rules necessary?
  • reasons for renewed ATO focus on thin capitalisation
  • to whom do the Australian thin capitalisation rules apply
  • a recap of the key features of the rules
  • different measurement techniques
  • interaction with the debt/equity rules
  • interaction with Part IVA
  • fixing thin capitalisation breaches - some tips and traps
  • completing a thin capitalisation schedule in practice
  • practical case studies.

Author profiles

Anthony Klein CTA
Anthony Klein, CTA is a Senior Tax Partner of PwC, based in Melbourne, and has over 22 years professional experience as a corporate, international tax and M&A tax specialist. Anthony leads PwC's corporate tax team in Melbourne, comprising of 22 partners and approximately 80 staff, and has been PwC's international tax leader for the Asia Pacific region. Anthony is the principal tax adviser to a large number of companies in the e-business sector. His clients range from some of Australia's largest multinational and publicly listed internet companies, to high growth businesses and earlier stage technology start-ups. He has assisted a number of corporate groups in the technology sector to structure their international investments, including through leading and advising upon cross-border acquisitions, international ownership and financing structures. - Current at 04 May 2017
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James Strong ATI
James Strong is a Partner in the Corporate Tax practice of PwC with over 14 years professional experience. James leads the firm’s Energy and Mining Tax practice and works extensively with resource companies both in Australia and internationally. James is heavily involved in supporting companies with the implementation of the MRRT and expanded PRRT and is a member of the ATO NTLG Resource Rent Tax Sub-committee (representing the ICAA). - Current at 09 May 2017
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Individual sessions

Thin Capitalisation: Is Debt a Dirty Word?

Author(s):  Anthony KLEIN,  James STRONG

Materials from this session:

Further details about this event:


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