Debt Equity Finance

Asset financing/thin capitalisation/infrastructure update

Source: QLD

Published Date: 13 Feb 2013

 

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There are radically divergent views emerging in relation to the interpretation of control and significant influence particularly in the context of minority shareholdings and shareholder arrangements. The flow-on impact upon provisions including Div 6C, debt/equity rules, interest deductibility, thin capitalisation and Div 250 is a contentious issue. This paper examines those issues and some other related recent developments in the context of project financing and consortium investment structures, in particular:

  • control, negative control, sufficient influence and connected entities in the context of Div 6C, Div 974-80 and thin capitalisation
  • thin capitalisation issues including related party debt rules and the ATO view of 820-39
  • changes to the definition of “limited recourse debt”.

Individual Session

Asset financing/thin capitalisation/infrastructure update

Author(s): Steve Ford CTA , Arash Azimi

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Debt Equity Finance Investment M&A Thin capitalisation Trusts 2013

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