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Australian Thin Capitalisation Reforms and Related Issues

October 17, 2023 @ 5:30 PM - 9:30 PM

Tuesday, 17 October 2023

Location: DLA Piper
Level 22, No 1 Martin Place, Sydney

Arrival from 5:30 pm.

Seminar commences at 5:45 pm, followed by refreshments and networking.

The IFA Australian Branch is pleased to invite you to the following in person event (livestreamed for interstate participants).

The Australian Senate Economics Legislation Committee has secured a time extension to report on the Tax Bill currently before the Parliament which contains, amongst other things, significant reforms to Australia’s thin capitalisation regime.

The new legislation proposes significant changes for multinational enterprises (non-bank/non-financial entities), particularly impacting those involved in capital intensive industries including economic and social infrastructure, property and energy and natural resources.

The transition to the OECD’s earnings-based model from the existing safe harbour test and arm’s length debt tests – as well as an additional integrity measure dealing with debt creation schemes – has raised various issues and concerns.

We will also examine the interaction of these thin capitalisation reforms and Australia’s transfer pricing rules.

Please join us for this timely and insightful in-person panel discussion.


Jock McCormack
Member of the Executive Committee (and Treasurer), Australian Branch of IFA, Chairman, Tax Committee of Infrastructure Partnerships Australia and Senior Tax Partner, DLA Piper

Jock advises a broad range of Australian and foreign based multinational corporations and funds, and is a leading international tax lawyer based in Sydney. He has previous international tax experience based in New York and New Zealand. Jock is an advisor to the Australian Treasury on the Tax Treaties Advisory Panel and the Digital Tax Working Group. He is a graduate of Economics and Law from the University of Sydney and has had guest lecturing roles at the University of Technology, Sydney and New York University.

Chloe Burnett SC
Vice – President, Australian Branch of IFA, Barrister, The NSW Bar

Chloe Burnett specialises in tax litigation. She has an interest in the taxation of cross-border financing, having appeared in the SingTel and Chevron transfer pricing cases, advised in relation to a number of other disputes in this area, and researched and published papers on thin capitalisation and transfer pricing of financial transactions. Before becoming a barrister, Chloe worked as a solicitor at Allens and worked as an Associate to the Hon. Justice Edmonds of the Federal Court. She also worked for Macquarie Bank in Sydney and Slaughter and May in London.

Richard Lambkin
Partner, M&A Tax, Deloitte

Richard is a partner at Deloitte with over 25 year’s experience advising both private sector and government clients on tax aspects of major economic and social infrastructure transactions – particularly in the energy, transport and other utilities sectors. This includes tax structuring advice and due diligence for M&A, government asset privatisations, schemes of arrangement, refinancings, restructures and greenfield development transactions. Richard regularly consults with the ATO and Treasury on tax policy matters and has negotiated a wide range of private rulings and other ATO products to facilitate successful transaction completion. Earlier in his career, Richard spent two years in London advising a range of global funds and asset managers on fund structuring and cross border transactions.

Rhys Manley
Assistant Commissioner, ATO

Rhys Manley is an Assistant Commissioner in the Policy Analysis and Legislation division of the Australian Taxation Office. Rhys’ focus is on multinational and treaty-related tax policy.


October 17, 2023
5:30 PM - 9:30 PM


DLA Piper – Sydney
Level 22, No 1 Martin Place
Sydney, NSW Australia
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