DEVELOPMENTS AFFECTING PREFERENCE SHARE FUNDING (HYBRID EQUITY INSTRUMENTS AND THIRD PARTY BACKED SHARES)

Tuesday, December 18, 2012
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The TLAB contains a proposal to amend sections 8E (the taxation of hybrid equity instruments) and 8EA (third party backed shares). The proposed amendments to section 8E will be implemented in two phases; the first phase essentially restores section 8E to its prior form (before it was amended by the Taxation Laws Amendment Act of 2011 (“TLLA”). The second phase will replace the current section with a new section.

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