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International Tax Series - Part 4: Acquisition: AusCo acquires a foreign business

Published on 28 Oct 2020 | Took place at Online, National

This session covered:

  • choice of acquisition vehicle
  • entity versus asset acquisition
  • tax due diligence, warranties and indemnities etc
  • funding of acquisition – equity from Australian parent (s 25-90)
  • financing – transfer pricing, hybrid mismatch rules, foreign income tax offsets for interest withholding tax, forex/swaps etc
  • thin capitalisation, DPT, CFC
  • repatriation considerations.

Individual sessions

Acquisition: AusCo acquires a foreign business

Author(s):  Sylvester Urban,  Kai-Chen Lamb,  Michael EVANS,  Cassandra Hamill

This paper covers:

  • overview: case study and scope
  • scenario A: acquisition of a Hong Kong agent (entity vs asset acquisition)
  • scenario B: treaty shopping structure
  • scenario C: funding via hybrid instrument.
Materials from this session: