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Thin capitalisation presentation
Published on 19 Sep 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE
This presentation covers:
- some aspects of foreign control
- the role of accounting standards
- the arm's length debt concept
- the 'safety' of safe harbour?
- the relevance of 'association'.
Author profile
Geoffrey Dunn
Geoffrey was admitted this year as a Solicitor of the NSW Supreme Court. From 1988 to 2000 Geoffrey was a Corporate Tax Partner with PricewaterhouseCoopers (PwC), and since 2001 has been engaged in a technical advisory role for that firm as a Technical Director. As part of his technical focus at PwC, Geoffrey has specialised in the debt and equity and thin capitalisation rules. - Current at 12 December 2007
This was presented at International Tax Masterclass .
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Individual sessions
Foreign hybrid entity rules - close but not close enough
Author(s): Neil BILLYARDMaterials from this session:
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Changes to the foreign tax credit regime - a high level summary
Author(s): Jeremy HIRSCHHORNMaterials from this session:
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Thin capitalisation - a selection of issues
Author(s): Geoffrey DUNNMaterials from this session:
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Withholding tax considerations
Author(s): Justin CHERRINGTON, James WILLISMaterials from this session:
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Interpretation of double tax agreements
Author(s): Richard SHADDICKMaterials from this session:
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Substantial equipment
Author(s): Adrian O'SHANNESSYMaterials from this session:
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Strategies for managing offshore taxation obligations and risks
Author(s): Margherita ANTONELLI, Jon DOBELLMaterials from this session:
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The new withholding obligations
Author(s): Andrew MILLSMaterials from this session:
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