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Related party financing – State of play presentation


This presentation covers:

  • state of play: ATO & advisor perspectives on financing
  • credit ratings - advisor perspective practical considerations
  • guarantees - advisor perspective
  • PCG 2017/4 - advisor perspective
  • PCG 2017/4 - advisor perspective cost of funds
  • conducting financing disputes – advisor perspective.

Author profiles

Shahzeb Panhwar
Shahzeb Panhwar is an Assistant Commissioner in the Public Groups and International area of the ATO and heads up the International Tax Structuring practice. In this role Shaz has responsibility for related party financing, thin capitalisation and thin capitalisation. Previously, Shaz’s roles have included overseeing PGI’s disputes strategy, the ATO’s international engagement programs and management of the Docklands audit teams. - Current at 16 July 2021
Dr Niv Tadmore CTA
Photo of author, Niv TADMORE Dr Tadmore is a Band 1 practitioner leading the Australian tax team of international law firm Jones Day. He has vast experience working for more than 20 years with large-market taxpayers from diverse industries, such upstream and downstream energy and resources, infrastructure, digital and tech, and pharmaceutical. The team is known for its hands-on practical approach to the prevention and resolution of tax disputes. Niv has represented the Tax Institute and Law Council on various ATO and Treasury Committees. He is a global Vice-President of the International Fiscal Association and the President of the Australian Branch. Niv is also a member of two tax academic boards: Melbourne University and New York University. - Current at 30 November 2020
Click here to expand/collapse more articles by Niv TADMORE.


This was presented at 51st Western Australia State Convention .

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Individual sessions

What’s current and where to next with the R&D tax incentive – An adviser’s and administrator's perspective

Author(s):  Steve Carroll,  Scott Parkinson,  Greg Thomas

Materials from this session:

Related party financing – State of play

Author(s):  Shahzeb Panhwar,  Niv TADMORE

Materials from this session:

What do self-driving cars, game-playing robots and tax have in common?

Author(s):  Belinda TOWNSEND,  Zane Duncalf

Materials from this session:

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