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Alternative assets insights: Related party financing in the infrastructure sector


This article considers the relevance of recent tax developments relating to debt pricing to cross-border related party financing in the infrastructure sector.


Author profiles

James Nickless
James Nickless is a tax partner specialising in transfer pricing and international tax at PwC. James has significant experience advising on cross-border funding structures from a transfer pricing and international tax perspective. James has advised a variety of infrastructure investors in relation to their capital structures as well as cross-staple lease pricing.James has been involved with the ATO and Treasury consultation process in relation to guidance on related party debt arrangements, the diverted profits tax and anti-hybrid rules. James is a Member of Chartered Accountants Australia & New Zealand. - Current at 05 May 2018
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Gareth Kirkby
Gareth Kirkby is a Senior Manager at PricewaterhouseCoopers and has over three years tax experience in the Australian domestic market. He previously worked in the UK, gaining corporate tax experience with a broad range of clients and markets. Gareth’s clients include several venture capital limited partnerships and he has experience in providing tax advice to all his clients in relation to structuring, restructuring, profit repatriation and exit strategies - Current at 28 May 2008


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