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.
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