ITAA 1936 s 23AH

OECD hybrid mismatch rules - concept of structured arrangement

Income tax - the use of internal derivatives by multinational banks

Central management and control test of residency: identifying where a company's central management and control is located

Compendium

Intangibles migration arrangements

Compendium

Income tax: is an amount that is a cost in relation to a debt interest covered by paragraph 820-40(1)(a) of the Income Tax Assessment Act 1997 (ITAA 1997) deductible under section 25-90 of the ITAA 1997 (or, alternatively, under subsection 230-15(3) of the ITAA 1997) where that amount is incurred in earning income that meets the requirements of both section 23AH of the Income Tax Assessment Act 1936 and section 768-5 of the ITAA 1997?

Compendium

Income tax: Interpreting Australia's Double Tax Agreements

Income tax: Permanent establishment - What is 'a place at or through which [a] person carries on any business' in the definition of permanent establishment in subsection 6(1) of the Income Tax Assessment Act 1936?

Income tax: branch funding for multinational banks

Income tax: entitlement to foreign income tax offsets under section 770-10 of the Income Tax Assessment Act 1997 where income is derived from investing in fiscally transparent foreign entities

Income tax: satisfying the 'carrying on a business at or through a permanent establishment' requirement in section 23AH of the Income Tax Assessment Act 1936 where a company is taken to have a permanent establishment (PE) in relation to substantial equipment

Income tax: proposed Special Dividend and Lion Nathan Limited Scheme of Arrangement

Income tax: off market takeover of Corporate Express Australia Limited and Special Dividend

Income tax: restructure of Spark Infrastructure

Income tax: off market takeover of Ammtec Limited

Income tax: return of capital - nib holdings limited

Income tax: off-market takeover of Crane Group Limited and Special Dividend

Cross-Border Round Robin Financing Arrangements