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2019 National Infrastructure Conference

Published on 16 May 2019 | Took place at Park Hyatt Melbourne, Melbourne, VIC

This event covered topics that include staples reform legislation, renewable energy, PPPs and trends in tax litigation.

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Individual sessions

“If you build it, they will come” – An increasingly diverse and complex energy market brings with it ... Tax complexity

Author(s):  Richard BUCHANAN,  Aaron Khoury

This paper covers:

  • UK substantial shareholding exemption
  • large-scale generation shortfall charges
  • proxy revenue swaps
  • impact of the stapled structure reforms on the renewable energy industry.

 

 

 

Materials from this session:

Cross staple arrangements – The cross roads

Author(s):  Adrian VARASSO

This paper covers:

  • history of stapled arrangements
  • use of stapled securities for investment in infrastructure
  • the Stapled Structure Act.
Materials from this session:

The seduction of debt in an infrastructure context

Author(s):  Paul ABBEY,  Nathan De Zilva

This paper covers:

  • current legislative framework
  • proposed Scheme Aggregation Rule
  • taxation developments
  • integrity of the proposed Scheme Aggregation Rule in the current taxation climate.

 

 

 

Materials from this session:

Infrastructure market and trends/outlook

Author(s):  Nick Forster

This presentation covers:

  • focus on long term infrastructure planning – Melbourne
  • what are investors saying about the Australian environment?
  • regulatory environment – energy policy
  • heating and cooling decarbonisation.

 

 

 

Materials from this session:

ATO keynote speaker address - Current issues in the infrastructure sector

Author(s):  Rebecca SAINT

This presentation covers:

  • tax contribution: large corporate groups
  • supporting community confidence
  • how this informs administration
  • top 100 and top 1000 programs
  • prevention and resolution of disputes.

 

 

 

 

Materials from this session:

US tax reforms and BEPS measures

Author(s):  Justin Davis,  Landon McGrew

This presentation covers:

  • overview of US tax reform changes
  • impact of US tax reform on foreign investment in US infrastructure
  • Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”)
  • BEPS related changes.

 

 

Materials from this session:

Trends in tax litigation

Author(s):  Kristen DEARDS

This presentation covers:

  • ATO approach to audits
  • ATO approach to litigation
  • what type of cases are litigated?
  • ATO Code of Settlement
  • negotiating a settlement with the ATO
  • use of expert reports.

 

 

 

Materials from this session:

Hybrid mismatches & infrastructure

Author(s):  Julian PINSON,  Rueben Pace

This presentation covers:

  • hybrid mismatch rules: brief recap
  • ATO experience to date
  • impact on infrastructure
  • changes to the rules: announced and potential future changes.

 

 

Materials from this session: