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Sharp edges in a modular world paper
Published on 18 Sep 08
This paper covers:
- financing deductions - an update
- debt equity issues in the context of cross border financing
- effectively non-contingent obligations: TR 2008/3 - the last word?
- Section 974-80 - where to now?
- Australia's transfer pricing regime - interaction between our treaties and Division 13
- transfer pricing and thin capitalisation - is there a safety in safe harbours? TD 2008/20, TD 2007/D20 and ATO Discussion Paper 08/7290
- the relevance of foreign law consequences to the domestic law.
Author profile
Ian Stanley CTA
Ian Stanley is a barrister whose practice at the Sydney Bar focuses on revenue law. Ian holds bachelor degrees in Economics and Law from the Australian National University and a Masters of Law from the University of Sydney. Ian has advised extensively on matters concerning residence. - Current at 12 July 2013
This was presented at International Tax Masterclass .
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Foreign entities – Characterisation and treatment for Australian tax purposes
Author(s): Alison RODI, David WATKINSMaterials from this session:
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Sharp edges in a modular world
Author(s): Ian STANLEYMaterials from this session:
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GST and the Internet: Don’t get caught in the web!
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Business profits and permanent establishments
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