Interest payable on borrowed funds or on amounts owing by reason of the operation of the law (for example interest that may be payable on statutory debts such as tax owing) in relation to an income earning activity is a significant (potential) deductible expense throughout the Commonwealth. The traditional “form ” approach derived from the leading decision IRC v Duke of Westminster [1936] AC 1 requires that the underlying transaction giving rise to the interest, and the interest itself, be characterised according to the legal rights and obligations created evident from the objective intention of the parties. On the other hand, an “economic substance ” approach allows for the same characterisation to arise having regard to the economic conse...
M.Comm.The purpose of this study is to discuss the deductibility of interest paid. Interest income i...
This paper reviews the policy case for restrictions on the deduction of interest expense as a necess...
This paper proposes and evaluates alternative methods for addressing the tax treatment of interest e...
Interest payable on borrowed funds or on amounts owing by reason of the operation of the law (for ex...
During the last decade, the judiciary and policy makers in both Canada and Australia have struggled ...
[Extract] The rules relating to the deductibility of interest in Australia have long been contentiou...
Thesis (M.Com.)-University of KwaZulu-Natal, 2004.For any expenditure to qualify as a deduction agai...
In its recent decision in St George Ltd v. Commissioner of Taxation, the Federal Court of Australia ...
A Taxation Ruling and various cases have recently created debate on the topic of the deductibility o...
The deductibility of interest expense under the Income Tax Act has been permitted generally where bo...
A research report submitted to the Faculty of Commerce, Law and Management, University of the Witwat...
Thesis (MCom (South African and International Taxation))--North-West University, Potchefstroom Campu...
The deduction of interest expenditure, for the purpose of calculating the South African taxable inco...
Obwervers of the federal tax scene have often noted a recurring phenomenon which enlivens the day-to...
In the United States, generally all interest payments are deductible. In Canada, by contrast, only i...
M.Comm.The purpose of this study is to discuss the deductibility of interest paid. Interest income i...
This paper reviews the policy case for restrictions on the deduction of interest expense as a necess...
This paper proposes and evaluates alternative methods for addressing the tax treatment of interest e...
Interest payable on borrowed funds or on amounts owing by reason of the operation of the law (for ex...
During the last decade, the judiciary and policy makers in both Canada and Australia have struggled ...
[Extract] The rules relating to the deductibility of interest in Australia have long been contentiou...
Thesis (M.Com.)-University of KwaZulu-Natal, 2004.For any expenditure to qualify as a deduction agai...
In its recent decision in St George Ltd v. Commissioner of Taxation, the Federal Court of Australia ...
A Taxation Ruling and various cases have recently created debate on the topic of the deductibility o...
The deductibility of interest expense under the Income Tax Act has been permitted generally where bo...
A research report submitted to the Faculty of Commerce, Law and Management, University of the Witwat...
Thesis (MCom (South African and International Taxation))--North-West University, Potchefstroom Campu...
The deduction of interest expenditure, for the purpose of calculating the South African taxable inco...
Obwervers of the federal tax scene have often noted a recurring phenomenon which enlivens the day-to...
In the United States, generally all interest payments are deductible. In Canada, by contrast, only i...
M.Comm.The purpose of this study is to discuss the deductibility of interest paid. Interest income i...
This paper reviews the policy case for restrictions on the deduction of interest expense as a necess...
This paper proposes and evaluates alternative methods for addressing the tax treatment of interest e...