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The future of hybrid financing in Australia paper
Published on 09 Oct 14 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This paper covers:
- what is hybrid financing?
- a short Australian tax history of hybrids
- Subdivision 768-A
- the action 2 paper
- inbound hybrid financing
- outbound hybrid financing
- practical considerations in applying the action 2 recommendations.
Author profiles
Craig Church
Craig is a Principal in the Tax Insights & Policy area at Deloitte in Sydney. Craig has almost 20 years experience advising clients on corporate and international tax matters including cross-border financing and acquisitions, tax consolidation and thin capitalisation matters. In his previous role at EY, Craig also spent 9 months working on the Australian Tax Desk in New York. - Current at 02 June 2015
This was presented at International Masterclass .
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Australia and the digital economy: A case study
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The future of hybrid financing in Australia
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Future directions in transfer pricing arising under the BEPS recommendations
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Dealing with a BEPS based tax review
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