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?
Current at 22 February 2013
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