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Securitised lease/licence arrangements paper

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DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 28 May 15 by VICTORIAN DIVISION, THE TAX INSTITUTE

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.

 

Author profile

Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. Martin represented the taxpayer in Shell Energy v Commissioner of Taxation before the Federal Court, Full Federal Court and High Court. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. Martin has extensive experience in contentious matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 28 September 2022
Click here to expand/collapse more articles by Martin FRY.

 

This was presented at National Infrastructure Conference .

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