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Current issues facing corporates in interpreting the debt equity rules in a cross border context paper

Published on 02 Nov 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers current issues facing corporates in interpreting the debt equity rules in a cross border context, including:

  • what is a non-contingent obligation?
  • how do the debt/equity rules interact with the DTAs?
  • current issues when issuing or investing in hybrid instruments cross border.

Author profile

Martin Fry FTI
Martin is the Practice Leader of the Allens Tax Group. 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. In recent years, Martin has focused on contentious transfer pricing 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 27 June 2022
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This was presented at Annual Corporate Tax Intensive: Complex Tax Issues Uncorked .

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Transfer pricing implications of related party funding arrangements

Author(s):  Paul BALKUS

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The current cross border co-operation arrangements between revenue authorities

Author(s):  Jan Farrell

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