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Legislation
ATO documents that consider ITAA 1997 s 974
138 documents
Income tax: Macquarie Group Limited - Macquarie Group Capital Notes 4
Income tax: Westpac Banking Corporation - Westpac Capital Notes 6
DBG Global Enterprises Pty Ltd - customer equity scheme
Accessing private company profits through a dividend access share arrangement attempting to circumvent taxation laws
Thin capitalisation - Incorrect calculation of the value of 'debt capital' treated wholly or partly as equity for accounting purposes
Mischaracterised arrangements and schemes connected with foreign investment into Australian entities
Arrangements involving interposed offshore entities to avoid interest withholding tax
Convertible Notes
Convertible Notes - Non-Share Equity Interest, Division 974, Income Tax Assessment Act 1997
Convertible Notes - Non-Share Capital Account, Division 164, Income Tax Assessment Act 1997
Convertible Notes - Non-Share Distribution as a Frankable Non-Share Dividend
Convertible Notes - Return on a Debt Interest, Division 974, Income Tax Assessment Act 1997
Convertible Notes - Non deductible distribution, Section 26-26, Income Tax Assessment Act 1997
Division 974 - non share equity interests
Exception Provision: commercial debt forgiveness
Classification of certain converting preference shares under Division 974 of the ITAA 1997
Debt/Equity: whether short term trade finance gives rise to debt interest under Division 974
Debt/Equity: whether short term trade finance gives rise to debt interest exception under Division 974
Redeemable preference shares: debt interest under Division 974
Debt and Equity Financing: rate of withholding tax on a return on a debt interest under Division 974