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Foreign hybrids - Where are we now? paper

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Published on 14 Sep 11 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • background to Division 830
  • definition of “foreign hybrid”
  • application of the “foreign hybrid” definition to specific entities
  • partnership treatment of foreign hybrids
  • disposal and cost base issues.

Author profiles

Andrew Hirst CTA
Andrew is a Partner and Head of Financial Services at Greenwoods & Herbert Smith Freehills. Andrew advises on a range of corporate and banking-related tax issues with a particular focus on financial and international transactions. Andrew has worked with Treasury and the ATO on various areas of tax reform that impact the financial services industry. - Current at 16 November 2021
Click here to expand/collapse more articles by Andrew Hirst.
Julian Pinson
Julian Pinson, FTI is a Partner at PwC. Julian advises on a wide range of tax matters, with a focus on banking and financial services and M&A. Julian has particular expertise in cross-border finance, TOFA, corporate restructures, debt and equity raisings and M&A. - Current at 02 November 2023
Click here to expand/collapse more articles by Julian PINSON.

 

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