Published on 18 Feb 15
by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper covers:
- effect of tax treaties on the operation of the reconstruction provision
- the "form" and "substance” of commercial or financial relations between entities
- what would independent parties dealing wholly independently have done?
- how do reconstructed transactions affect the calculation of tax payable?
- does section 815-140 rely on the operation of the reconstruction provisions in cases of excessive debt?
Ian is a Barrister, Ground Floor Wentworth Chambers.
- Current at
29 October 2019