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  Property Thin capitalisation Miscellaneous

Securitisation vehicles and limited recourse debt amendments

Source: New South Wales

Published Date: 16 May 2013

 

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Draft Taxation Determination TD 2012/D11 and the proposed amendments to Div 243 have the potential to adversely impact on project financing and securitisation activities.

This paper covers:

  • Securitisation structures:
    • what is s 820-39 aimed at
    • what are the ATO’s views?
    • is this just an issue for securitisation structures used in PPPs?
  • Limited recourse debt amendments:
    • what is limited recourse debt?
    • when do the provisions apply (refinancing, sale)?
    • can the provisions apply even if the debt is ultimately repaid in full?
    • how to calculate the “excessive deductions”, including examples.
Author(s)

Individual Session

Securitisation vehicles and limited recourse debt amendments

Author(s): Greig Hubbard ATI , Mark Hadassin CTA
Materials from this session:

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Property Thin capitalisation Miscellaneous Income tax 2013

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