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Thin capitalisation and AIFRS paper

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Published on 01 Nov 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the ATO draft determination on the TP and thin cap interaction
  • ATO draft discussion paper on intercompany funding arrangements and parent guarantees
  • impact of removal of debt creation rules
  • Section 25-85.

Author profile

Steven Gafinowitz
Larry of Ernst & Young is a Tax Partner in the Sydney office. He has over 20 year’s experience in the field of Australian tax, specialising in the financial services industry. Larry has advised Australian multinational companies, banks, private equity funds and hedge funds extensively on structuring investments in Australia and overseas and on cross-border transactions (including tax-effective financing and cash repatriation strategies). In addition, Larry also has significant M&A experience in the manufacturing, health care, retail and telecommunications industries. - Current at 26 September 2007

 

This was presented at Annual Corporate Tax Intensive: Complex Tax Issues Uncorked .

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