Source: The Tax Specialist Journal Article
Published Date: 1 Jun 2014
Capital management, including raising and returning capital, carries with it a range of taxation implications, some of which exhibit a degree of uncertainty. Much of that uncertainty arises from the practice of the ATO and the discretions afforded the Commissioner of Taxation under a number of specific integrity measures. This article is intended to provide an update on the key Australian income tax issues, ATO administrative practice, and current tax reviews for corporates and their shareholders, in relation to undertaking capital management initiatives.
The article is, broadly, in two parts. The first part considers capital raisings by non-financial corporates through the use of hybrid securities and rights issues that use so-called retail premiums. The second part deals with returning capital to shareholders, including share buy-backs, returns of capital, and tainting of the share capital account.
More by Richard Hendriks
Current issues in M&A demergers - Paper 22 Aug 2019
Current issues in M&A/demergers - Paper 23 May 2019
Current issues in MA/demergers - Presentation 23 May 2019
What's hot in 2012? - Presentation 07 Mar 2012
An update on the consolidation regime - Paper 19 May 2011
An update on the consolidation regime - Presentation 19 May 2011
M&A transactions - Presentation 14 Oct 2010
Merger & acquisitions transactions - Paper 14 Oct 2010
M&A: Scrip rollover restructure rules - Presentation 01 May 2009
More by Cameron Blackwood
PepsiCo falls flat for the ATO - Journal 20 Sep 2024
Undertaking M&A and restructures in an uncertain tax reform landscape - Journal 01 Aug 2024
Undertaking M&A and restructures in an uncertain tax reform landscape - Paper 22 May 2024
Retaining and rewarding employees post pandemic - Audio 18 Oct 2021
Retaining and rewarding employees post pandemic - Video 18 Oct 2021
Retaining and rewarding employees post pandemic - Paper 18 Oct 2021
Retaining and rewarding employees post pandemic - Presentation 18 Oct 2021
Topical issues and developments in M&A - Audio 21 Jan 2021
Topical issues and developments in M&A - Presentation 11 Nov 2020
Topical issues and developments in M&A - Video 11 Nov 2020
Sorry, this is subscriber only content.
To gain access to this material and much more - Subscribe Now.
(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).
Already a Subscriber? Login now
Already a Subscriber? Login now
Details
The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The Tax Institute
(ABN 45 008 392 372 (PRV14016))
("TTI")
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.
Tags