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National Infrastructure Conference

Published on 26 May 2016 | Took place at The Langham, Melbourne, VIC

Investment in infrastructure is critical for maintaining living standards and creating the conditions in which our economy can continue to grow. This event covers many issues that are relevant to the industry, including the meaning of “control” in the context of public trading trusts and the thin capitalisation rules, BEPs and global infrastructure, financing stapled structures, tax sharing and tax funding agreements, and an update on the managed investment trust (MIT) rules among other things.

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Individual sessions

Thin capitalisation - A focus on trusts

Author(s):  Steve FORD,  Angela Van

This paper covers:

  • thin capitalisation rules
  • worldwide gearing debt amount
  • exemption for 90% Australian assets test – section 820-37 of the ITAA 1997
  • exemption from thin capitalisation for special purpose entities – section 820-39 of the ITAA 1997
  • summary.
Materials from this session:

Towards justified trust between the ATO and the infrastructure industry

Author(s):  Jeremy HIRSCHHORN

This paper covers:

  • update from last year
  • what is justified trust?
  • what the ATO is doing to increase justified trust
  • what we need industry to do.
Materials from this session:

The imposition of Australian stamp duties on foreign entities

Author(s):  Costa KOUTSIS,  Angela Qian

This paper covers:

  • state taxes specifically imposed on foreign investors
  • the interaction between foreign legal regimes and Australian stamp duty laws
  • enforcement measures and impact of multilateral agreements and conventions.
Materials from this session:

Division 6C of the ITAA36 negative control

Author(s):  Terry MURPHY,  Julianne JAQUES

This paper covers:

  • Division 6C
  • principles of statutory construction
  • legislative history
  • ATO view
  • negative Control and s 102N(1)(b)
  • Where to from here?
Materials from this session:

Division 6C property funds - Land in the context of infrastructure

Author(s):  Chris PEADON

This paper covers:

  • overview of Division 6C
  • what is an “investment in land”?
  • what is “rent”?
  • when is an investment in land “for the purpose, or primarily for the purpose” of deriving rent?
Materials from this session:

Tax sharing and tax funding agreements in a project financing context

Author(s):  David WOOD

This paper covers:

  • tax sharing agreements
  • tax funding agreements
  • insolvency of a member.
Materials from this session:

ATO areas of compliance focus

Author(s):  Rhys MANLEY,  Craig SAUNDERS

This presentation covers:

  • public private partnerships
  • PPPs - capital characterisation of licence payment
  • PPPs - shifting profits into a trust
  • stapled structures
  • stapled structures – overshoot – unequal debt levels at the asset level.
Materials from this session:

The infrastructure market in Australia current themes and perspectives

Author(s):  John Pickhaver

This presentation covers:

  • key structural shifts are changing energy market dynamics
  • opportunity in current resource environment
  • Australia’s population to grow strongly largely flowing into our cities
  • Australian construction activity
  • infrastructure Australia priority list.
Materials from this session:

Section 974-80: The current state of play

Author(s):  Richard BUCHANAN,  Edward Consett

This paper covers:

  • how did we end up here?
  • where have all the finance trusts gone?
  • can asset trusts still lend across the staple?
  • where do we go from here?
Materials from this session: