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Asset financing/thin capitalisation/infrastructure update paper

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Published on 13 Feb 13 by QUEENSLAND DIVISION, THE TAX INSTITUTE

There are radically divergent views emerging in relation to the interpretation of control and significant influence particularly in the context of minority shareholdings and shareholder arrangements. The flow-on impact upon provisions including Div 6C, debt/equity rules, interest deductibility, thin capitalisation and Div 250 is a contentious issue. This paper examines those issues and some other related recent developments in the context of project financing and consortium investment structures, in particular:

  • control, negative control, sufficient influence and connected entities in the context of Div 6C, Div 974-80 and thin capitalisation
  • thin capitalisation issues including related party debt rules and the ATO view of 820-39
  • changes to the definition of “limited recourse debt”.

Author profiles

Stephen Ford CTA
Steve Ford, CTA, is a Tax Partner at PwC, specialising in M&A in the infrastructure, PPP and energy sectors. Steve is a member of the IPA Tax Committee. Steve was previously an Executive Director with Macquarie Capital, specialising in project finance and infrastructure. - Current at 26 June 2019
Click here to expand/collapse more articles by Steve FORD.
Arash Azimi
Arash is a Senior Consultant at PwC. - Current at 13 February 2013
Click here to expand/collapse more articles by Arash AZIMI.

 

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Asset financing/thin capitalisation/infrastructure update

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