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Interest withholding tax - Common issues paper


This paper covers:

  • overview of interest withholding tax
  • double tax agreement exemptions
  • Section 128FA: public offer test for eligible unit trusts
  • letter of credit facilities
  • offshore trust lender
  • Section 128AC: hre purchase arrangements
  • assessability of interest.

Author profiles

Ian Kellock CTA
Photo of author, Ian KELLOCK Ian is a Tax Partner at Ashurst and has extensive experience in Australian corporate and international tax, advising Australian and foreignowned banking and financial services groups. Ian’s practice primarily focuses on due diligence and structuring for mergers, acquisitions and divestments, financing transactions and group reorganisations. Ian has significant recent experience advising on all income tax aspects of financing and refinancing transactions and asset and debt reconstruction projects. - Current at 29 May 2019
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Bronwyn Kirkwood CTA
Bronwyn is a Senior Associate at Ashurst in Melbourne. Bronwyn’s practice is in direct tax, with an emphasis on financial services and general corporate tax issues. Bronwyn’s experience covers a broad range of matters, including providing income tax advice for structured financing arrangements, securitisations, PPPs and mergers and acquisitions. She has significant experience in advising on exemptions to the application of interest withholding tax. - Current at 29 May 2019
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James Sainty FTI
James is a Lawyer with Ashurst Australia. - Current at 29 May 2019


This was presented at 2019 Financial Services Taxation Conference .

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