The Federal Government’s announcement of proposed reforms to Australia’s thin capitalisation regime came with a sting in the tail for the infrastructure sector by combining the new 30 percent EBITDA test with a restriction on the use of the arm’s length debt test to ‘external debt’.
This session covers:
- Why now?
- The key features of the proposed 30 percent tax EBITDA test that is intended to replace the current safe harbour debt test
- What is ‘external debt’ under the arm’s length debt test
- Some case studies outlining the potential impact on common infrastructure financing structures; and
- What to consider when restructuring gearing.