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Cross examination: Debt defeasance: the ICI Australia Case ; Burrill's case at face value ; Fallout from energy case


The first article explains the facts and discusses the decision on the ICI Australia case, which could mean that the ATO may have to amend tax ruling IT2495. The second, although financial transactions are all about the time value of money, the courts continue to adhere to a face value approach. The most recent example4 is the Full Bench Court decision in Burrill v FCT. And the third, examines the High Court's recent decision on the Commissioner's appeal in FCT v Energy Resources of Australia Ltd generally is favourable to taxpayers, it raises issues that may now need to be addressed.

Author profiles

Prof Richard Vann CTA
Prof Richard Vann, CTA, is Challis Professor of Law at the University of Sydney and a Consultant at Greenwoods & Herbert Smith Freehills. He has also taught at NYU Law School, Harvard Law School and the University of London. He has held many government consultancies in Australia, including the Review of Business Taxation (1998 - 1999), the Review of International Taxation (2002 - 2003) and the Australian Taxation Office Public Rulings Panels on international and indirect taxation (1995-2007). Most recently, he has been involved in various Board of Taxation work on managed investment trusts and collective investment vehicles, the attribution of profits to permanent establishments and as a member of Treasury’s BEPS Advisory Group. Richard is the Editor-in-Chief of the IBFD Global Tax Treaties Commentaries now being progressively published. - Current at 14 July 2017
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Robert Allerdice
Photo of author, Robert Allerdice
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