This session outlines the new legislative provisions for 'debt' and 'equity' and highlight their practical application including:
- a review of the new definitions of 'debt' and 'equity'
- an analyses of when a 'contingent' obligation to make a payment will be regarded as a deemed dividend
- a review of the tax implications of non arms length shareholder loans
- a critique of the tax consequences for payers and payees under the new rules and;
- the lack of symmetry between the tax treatment of dividends and non share dividends