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Are your interest deductions at risk?

Published on 16 Aug 2001 | Took place at Leonda by the Yarra, Hawthorn, VIC

This seminar discusses the thin capitalisation regime; the effect the debt and equity rules will have on funding business transactions; and the general principles of interest deductibility.

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Individual sessions

Read the fine print: the impact of new debt and equity rules

Author(s):  Mark MORRIS This session outlines the new legislative provisions for 'debt' and 'equity' and highlight their practical application including:

  • a review of the new definitions of 'debt' and 'equity'
  • an analyses of when a 'contingent' obligation to make a payment will be regarded as a deemed dividend
  • a review of the tax implications of non arms length shareholder loans
  • a critique of the tax consequences for payers and payees under the new rules and;
  • the lack of symmetry between the tax treatment of dividends and non share dividends
    Materials from this session:

    • General principles of interest deductibility

    Author(s):  Anthony SMYTH This paper discusses the deductibility of interest for income purposes.

    Materials from this session:

    Thin capitalisation - the new regime

    Author(s):  Michael HAY This paper looks at the thin capitalisation rules in the context of:

  • 1st time applications to existing Australian based businesses and investors
  • investing or expanding offshore
  • how to pass the tests
  • grouping rules - how to use the excess debt capacity
  • transitional implications
    Materials from this session: