Tax
Tax » Capital Markets
Industries such as Energy & Resources are extremely debt as well as equity capital intensive and the tax treatment of instruments is critical to the financial and commercial outcomes.
Debt instruments result in a return to investors that is tax deductible to the issuer while equity instruments result in a return that is non-deductible but frankable. The difference is stark and the law complex.
The mix of debt and equity is also crucial to the overall tax result under the thin capitalisation laws. And the withholding tax treatment of returns paid to foreign participants in syndicated financing and debt issues cannot be understated. Corrs has the expertise and experience to deal with all these issues.
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Fortescue Metals Group
Fortescue’s US$2.04 billion senior unsecured note offering, and the follow on US$1.5 billion offering, was the first large scale unsecured high yield offering by an Australian corporate issuer and one of the largest note offerings by an Australian corporate in 2010. Corrs advised JP Morgan and RBS on all Australian income tax, withholding tax and GST issues.
MCC’s US$5.1 billion IPO
When China Metallurgical Group Corporation, a Chinese state owned corporation floated its subsidiary, Metallurgical Corporation of China on the Shanghai and Hong Kong stock exchanges, it was the second largest IPO in the world in 2009.
MoreOur Thinking
Federal Budget 2012-13: The major business tax measures
The Treasurer, the Hon Wayne Swan MP, has just delivered the most highly anticipated Budget speech for a long time. So what are the major business tax measures in the Budget that impact the Budget bottom line?
MoreNew South Wales stamp duty changes
An amending bill has been introduced into the New South Wales Parliament which will make significant changes to the corporate reconstruction exemption provisions and introduce a specific anti-avoidance measure into the landholder duty provisions.
MoreCorrs in Brief: Transfer Pricing - a changing landscape
Australia's domestic transfer pricing provision, Division 13 of the Income Tax Assessment Act 1936, was introduced in 1982. However, until 2008, there had been no substantive decision concerning its operation. Recent developments are set to change t
MoreCorrs in Brief: Taxation of gains derived by foreign residents on non-portfolio interests in mining companies
The ATO's recent decisions regarding Australia's capital gains tax regime highlight the importance of getting the sale/purchase price allocation right.
MoreCorrs in Brief: Announced changes to the Australian General Anti-Avoidance Rule (GAAR)
The government’s action is in direct response to concerns about recent court losses suffered by the Australian Taxation Office (ATO) in seeking to apply the GAAR to transactions or arrangements entered into by some of Australia’s largest taxpayers.
More
Navigating Stamp Duty investigations
What are the triggers for these investigations and what do you need to know if you are subject to one of those investigations?
MoreDoing Business In Australia
Australia is an exceptional place in which to do business. Find out how we can help you develop your business in Australia.
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The Tax Forum – Worth the wait?
Will this week’s Tax Forum put the wheels back on the tax reform cart? Jonathon Leek considers the Government’s record on tax reform and the likelihood of real and effective reform.
More
Transfer pricing: a complex and pervasive issue
Transfer pricing is an issue that has become more complex and pervasive as a result of the increasing globalisation of business.
More
Watch out, FIN48 is coming
Tax law is not a science, but it’s going to have to move in that direction
MoreOur Experience
Fortescue Metals Group
Fortescue’s US$2.04 billion senior unsecured note offering, and the follow on US$1.5 billion offering, was the first large scale unsecured high yield offering by an Australian corporate issuer and one of the largest note offerings by an Australian corporate in 2010. Corrs advised JP Morgan and RBS on all Australian income tax, withholding tax and GST issues.
MCC’s US$5.1 billion IPO
When China Metallurgical Group Corporation, a Chinese state owned corporation floated its subsidiary, Metallurgical Corporation of China on the Shanghai and Hong Kong stock exchanges, it was the second largest IPO in the world in 2009.
Corrs handled the Australian component of the US$5.1 billion IPO, comprising about 20% of the float. This included all the tax aspects such as a complex pre-IPO restructure, tax due diligence and the tax opinion for the investment bankers. Corrs Tax Team also acted on MCC’s acquisition of iron ore assets at Cape Lambert and Cape Preston in Western Australia.
Our Thinking
Watch out, FIN48 is coming
Tax law is not a science, but it’s going to have to move in that direction
Doing Business In Australia
Australia is an exceptional place in which to do business. Find out how we can help you develop your business in Australia.
Transfer pricing: a complex and pervasive issue
Transfer pricing is an issue that has become more complex and pervasive as a result of the increasing globalisation of business.
The Tax Forum – Worth the wait?
Will this week’s Tax Forum put the wheels back on the tax reform cart? Jonathon Leek considers the Government’s record on tax reform and the likelihood of real and effective reform.
Navigating Stamp Duty investigations
What are the triggers for these investigations and what do you need to know if you are subject to one of those investigations?
Federal Budget 2012-13: The major business tax measures
The Treasurer, the Hon Wayne Swan MP, has just delivered the most highly anticipated Budget speech for a long time. So what are the major business tax measures in the Budget that impact the Budget bottom line?
Corrs in Brief: Announced changes to the Australian General Anti-Avoidance Rule (GAAR)
The government’s action is in direct response to concerns about recent court losses suffered by the Australian Taxation Office (ATO) in seeking to apply the GAAR to transactions or arrangements entered into by some of Australia’s largest taxpayers.
Corrs in Brief: Taxation of gains derived by foreign residents on non-portfolio interests in mining companies
The ATO's recent decisions regarding Australia's capital gains tax regime highlight the importance of getting the sale/purchase price allocation right.
Corrs in Brief: Transfer Pricing - a changing landscape
Australia's domestic transfer pricing provision, Division 13 of the Income Tax Assessment Act 1936, was introduced in 1982. However, until 2008, there had been no substantive decision concerning its operation. Recent developments are set to change t
New South Wales stamp duty changes
An amending bill has been introduced into the New South Wales Parliament which will make significant changes to the corporate reconstruction exemption provisions and introduce a specific anti-avoidance measure into the landholder duty provisions.
Our Experts