This video is a filmed session from the NSW 9th Annual Tax Forum, PowerPoint slides are incorporated with the presentation. Recent cases show that the “divide” between the fruit and the tree remains a difficult one.
By considering High Court and Full Federal Court decisions, this session will explore the vexed issue of characterisation. This survey of cases included coverage of the Ausnet Transmission High Court decision (expenditure side), and a discussion on how these cases may have broader application to other items of business expenses and business income.
Eddy Moussa, CTA, is a practising tax lawyer with over 18 years experience in providing legal advice on taxation matters such as financing, international and domestic restructuring and merger and acquisition transactions. Eddy is a partner in the PwC Tax Controversy team. He provides legal advice to mainly multinational clients on taxation matters (including anti-avoidance), and supports clients in resolving disputes with the ATO. This work involves assisting clients under audit or investigation. Eddy also leads alternative dispute resolution processes, briefs counsel and provides anti-avoidance opinions. Eddy has also advised a number of multinational organisations on international tax issues, including cash repatriation, investment structuring, withholding tax and treaty issues.
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19 June 2018