Property Thin capitalisation Miscellaneous

Securitisation vehicles and limited recourse debt amendments

Source: New South Wales

Published Date: 16 May 2013


Draft Taxation Determination TD 2012/D11 and the proposed amendments to Div 243 have the potential to adversely impact on project financing and securitisation activities.

This presentation covers:

  • Securitisation structures??:
    • what is s 820-39 aimed at???
    • what are the ATO’s views?
    • ??is this just an issue for securitisation structures used in PPPs?
  • Limited recourse debt amendments??:
    • what is limited recourse debt?
    • ??when do the provisions apply? (refinancing, sale)??
    • can the provisions apply even if the debt is ultimately repaid in full???
    • how to calculate the “excessive deductions”, including examples.

Sorry, this is subscriber only content.

If you're not yet a subscriber, to gain access to this material and much more - Subscribe Now.

Already a Subscriber? Login now

Already a Subscriber? Login now

Individual Session

Securitisation vehicles and limited recourse debt amendments

Author(s): Greig Hubbard ATI , Mark Hadassin CTA


The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))


The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.


Property Thin capitalisation Miscellaneous Income tax 2013

Share this page