Property Thin capitalisation Miscellaneous

Securitisation vehicles and limited recourse debt amendments

Source: New South Wales

Published Date: 16 May 2013

 

Sorry, this content is for members only.

To get access to this and 25,000 other premium articles, books, videos and webinars sign up toour members program.

Already a Member? Login Now

Already a Member? Login Now

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.

Individual Session

Securitisation vehicles and limited recourse debt amendments

Author(s): Greig Hubbard , Mark Hadassin

Details

The material is copyright. Apart any fair dealing for the purpose of private study,

research critisism or review, as permitted under the copyright Act, no part may be rerpoduced 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.

This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Tags

Property Thin capitalisation Miscellaneous Income tax 2013

Share this page