ITAA 1997 s 974-B

Income tax: can the assignment of an intra-group debt or income stream to an entity that is not a member of the consolidated group give rise to a debt interest for the head company of the group under Division 974 of the Income Tax Assessment Act 1997?

Income tax: the interaction of Division 820 of the Income Tax Assessment Act 1997 and the transfer pricing provisions

Income tax: Keybridge Capital Ltd: return of capital and issue of Convertible Redeemable Promissory Notes

Debt/Equity: Redeemable Preference Share

Withholding Tax: dividends paid in respect of redeemable preference shares - rate of withholding tax determined under the United States Convention

Income tax: can the assignment of an intra-group debt or income stream to an entity that is not a member of the consolidated group give rise to a debt interest for the head company of the group under Division 974 of the Income Tax Assessment Act 1997?

Income tax: thin capitalisation - applying the arm's length debt test

Consolidation: Subsidiary member - Issue of non-debt interest preference shares to retirement village residents