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BEPS – Action Item 2 - Hybrids presentation

Published on 07 Feb 18 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • Australia’s response - update
  • expected timing
  • inbound financing
  • inbound MRPS – HFI Rule
  • reverse hybrid
  • imported mismatch.

Author profiles

Manu SRISKANTHARAJAH
Paul Korganow
Photo of author, Paul KORGANOW Paul Korganow, ATI, is the ATO Assistant Commissioner for the International Tax Structuring/BEPS Practice, Public Groups and International. Paul leads an International Tax Structuring team based in Melbourne and Sydney. He is also involved in strategy development and contribution to domestic and multilateral law reform around BEPS. Paul is the ATO Project Lead for BEPS Action 2, the Australian ATO representative at OECD Working Party 11 and represented the ATO on the Board of Taxation Working Group looking at the domestic implementation of the OECD Anti-Hybrid Rules. Paul was previously a Partner at two Big 4 firms in their International Tax and M&A groups. - Current at 16 February 2018
Click here to expand/collapse more articles by Paul KORGANOW.

 

This was presented at 2018 Financial Services Taxation Conference .

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Individual sessions

M&A in financial services

Author(s):  Paul ABBEY,  Jeanelle MENEZES

Materials from this session:


Residence – Central management & control

Author(s):  Stuart Dall,  Bob Deutsch,  Richard EVANS

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The ATO’s approach to significant financial services tax issues

Author(s):  Jeremy HIRSCHHORN

Materials from this session:


Macro economic outlook and implications for taxation

Author(s):  Shane Oliver

Materials from this session:








Australia’s hybrid mismatch rules: Application and interactions

Author(s):  Manu SRISKANTHARAJAH

Materials from this session:

Tax transparency initiatives – The current state of play

Author(s):  Chris Vanderkley,  Helen Kelly

Materials from this session:

Stapled groups

Author(s):  Andrew Hirst

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