Reconstructing financing transactions: A focus on the debt and equity rules, Division 815 and thin capitalisation presentation

Stuart Landsberg

Stuart Landsberg is an international tax partner with over 19 years of experience advising clients on a range of issues relating to their cross-border investments and holdings. He has recently returned to Australia after a five year assignment to PwC US, where he led PwC's Australian Tax Desk and where he counselled US and Australian taxpayers in respect of their investments in the respective countries. Notwithstanding his specialisation in international tax, Stuart has a broad-based practice with a deep specialisation in the taxation of M&A and assisting clients to favourably resolve tax controversies too. He has a similarly broad-based industry focus, starting his career with a focus on energy and resources, but more recently advising clients in the technology sector and also advising financial sponsors and alternative asset managers in relation to their investments across the economy. - Current at 03 June 2025

Tariq Rasool

Tariq is a Director in PwC Australia’s Global Tax team with 11 years experience in international tax and transfer pricing; specialising in mergers and acquisitions, inbound and outbound structuring/financing, and revenue authority engagement. While working with PwC in Perth, Tariq has worked predominantly with companies in the mining & resources, and mining services industries. He has also spent 4 years in Sydney working with clients across multiple industries, including manufacturing, telecommunications, oil & gas, retail and technology. Tariq has a keen interest in the development of international taxation and transfer pricing practices and the associated interplay between various countries, particularly in light of the role played by the OECD in the global tax community. - Current at 30 November 2022