After years of consultation the new tax measures for property and infrastructure projects have been introduced into Parliament in Tax Laws Amendment (2007 Measures No. 5) Bill 2007. The new rules will generally be relevant for transactions between private sector organisations and either tax exempt or non-resident parties entered into on or after 1 July 2007.
After reviewing the gateways into these new rules and the carve-outs, this seminar examined the application of the new rules to both public/private partnership transactions and general property transactions, including:
- structuring alternatives
- transitional operation of the existing section 51AD and Division 16D, including the impact of the new rules on contingent equity arrangements
- the treatment on termination of transactions
- overseas transactions.