11-20 of 146 results
Conexa and statutory severance: when a pipeline is 'land'
'Statutory severance' provisions have a significant impact on the application of tax laws to owners of built infrastructure. The New South Wales Court of Appeal's recent decision in Conexa Sydney Hold ...
Stamp duty complexities in Sale and Purchase Agreements: insights from Van Dairy
The recent Tasmanian case of Van Dairy suggests that an agreement to procure a sale of property might be liable to duty as an agreement for sale, even if the owner of the property is not a party to it. considered the status of a Sale and Purchase Agreement (SPA) in the context of stamp duty. ...
Exposure draft legislation for Australian 'hybrid mismatch rules' released
Treasury has released for consultation exposure draft legislation to introduce new rules to neutralise the effects of hybrid mismatch arrangements in accordance with Action Item 2 of the OECDG20 Base Erosion and Profit Shifting Project Multinational groups with cross-border arrangements or proposing ...
National Transfer Pricing Conference: Intragroup financing — More than just whether the price is right
Toby Knight, Anna Sartori and Gidon Waller have published a paper examining the application of transfer pricing, the debt deduction creation rules (DDCR), the new thin capitalisation rules and the general anti-avoidance rule (GAAR) to intragroup financing arrangements. ...
Allens advises Global Switch on $2.12b sale of Australian data centre operations
HMC has agreed to acquire 100% of Global Switch Australia Holdings (GSA) as part of its broader strategy to establish a global digital infrastructure platform. GSA's two adjoining data centres in ...
Allens advises vendors on Queensland Airports sale
The firm acted as consortium counsel for Macquarie Asset Management-managed The Infrastructure Fund, State Super and Australian Retirement Trust on the sale of their combined interest to a consorti ...
Overview of state and territory Budgets 2024–25
Budgets for 2024-25 have now been delivered in all Australian jurisdictions. Two common themes are incremental increases to existing taxes, and 'cost of living' tax relief. We examine the Budget announcements that will be relevant to business and industry. ...
Has the ATO tolled the bell for demerger and acquisition scheme structures?
The Deputy Commissioner of Taxation has formally refused a request from AMA Group Limited for demerger relief in connection with a demerger and acquisition transaction involving private equity firm Blackstone casting doubt on the availability of capital gains and income-tax relief for transactions ...
Victorian stamp duty for industrial and commercial properties transitions to annual tax from 1 July 2024
From 1 July 2024, under the Commercial and Industrial Property Tax Reform Act 2024 (Vic) (the Act), which seeks to implement 'transformational' tax reform for commercial and industrial property, such property will be subject to stamp duty for a final time when it is next sold or otherwise transacted ...
Tax Forum: Limiting Debt Deductions - a look at the new thin capitalisation rules
In 2022, the then newly elected Australian Labor Government published a Consultation Paper in which it confirmed that it would undertake the ambiguous (and unenviable) task of comprehensively reviewing Australia's interest limitation – or thin capitalisation – regime. ...