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Select issues in cross border debt financing paper

Published on 05 Mar 10 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • tax aspects of debt financing
  • deductibility of returns
  • limits on deductibility.

Author profile

Kirsten Fish CTA
Photo of author, Kirsten FISH Kirsten Fish is ATO Second Commissioner for Law Design and Practice. In this role, Kirsten has overall responsibility for the ATO’s law practice, including law interpretation, public advice and guidance, independent dispute prevention and resolution, and the ATO’s role in policy and law design. The Law Design and Practice Group serves the community, government and clients by ensuring the tax and super laws are informed, understood, administered and applied with confidence and integrity and is the respected and trusted authoritative voice of the Commissioner on matters of law and revenue analysis. Kirsten joined the ATO in 2014 and the ATO’s Chief Tax Counsel from 2015, one of the highest legal authorities within the ATO, leading the Tax Counsel Network and providing technical leadership in relation to significant tax issues, cases and rulings. Kirsten was acting Second Comissioner for 12 months before being formally appointed to the role in October 2021. Prior to joining the ATO, Kirsten was a tax Partner at Clayton Utz with a focus on the financial services industry and providing finance and investment transaction advice. Kirsten holds a Bachelor of Commerce (Accounting), Bachelor of Laws (First Class Honours) and Masters of Law (Tax). - Current at 04 November 2021
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