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National Infrastructure Conference

Published on 28 May 2015 | Took place at The Langham, Melbourne, VIC

This event covered many issues that are relevant to the industry, including the capital/income distinction in an infrastructure context, key tax issues on privatisations, financing stapled structures, structuring capital contributions tax effectively and MIT rules in an infrastructure context. There was also a session on ATO guidance on infrastructure investment from the ATO’s Chief Tax Counsel.

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Individual sessions

Issues on privatisation

Author(s):  Richard BUCHANAN,  Cristina Wolters

This presentation covers:

  • balancing technical and practical issues through a privatisation process
  • technical issues
  • is the asset a fixture?
  • Division 58
  • Division 43 - “your area”
  • Division 250 unintended application.

 

Materials from this session:

ATO guidance on infrastructure investment

Author(s):  Jeremy HIRSCHHORN

This presentation covers:

  • environment
  • existing guidance
  • project team
  • how we are providing certainty
  • new guidance
  • key concerns.
Materials from this session:

MIT rules in an infrastructure context

Author(s):  Steven ECONOMIDES,  Sally Dole

This paper covers:

  • infrastructure and MITs - synergising the privatisation wave
  • the MIT rules - where are we now and where are we going?
  • the prominence of MITs in infrastructure investment
  • interplaying “arm’s length” and MITs - can it work?
Materials from this session:

GST & infrastructure timing is everything

Author(s):  Rhys PENNING

This paper covers:

  • relevant legislative provisions
  • supplies and acquisitions
  • construction of the facility
  • impact ofrental securitisation
  • transaction and bid costs.
Materials from this session:

Securitised lease/licence arrangements

Author(s):  Martin FRY

This paper covers:

  • securitised lease/licence arrangements
  • income tax aspects of securitised lease/licence arrangements
  • Division 250: assets put to a tax preferred use
  • tax preferred use of the asset
  • Finance Co and the Division 230 TOFA provisions
  • Finance Co and thin capitalisation.

 

Materials from this session: