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Thin capitalisation

Published on 14 Mar 02 by NATIONAL EVENTS, TAXATION INSTITUTE OF AUSTRALIA

This convention paper discusses thin capitalisation, with a focus on: how to choose between the three methods, what values to use for the 75% of assets test, how does the arm's length test really work, investment in subsidiaries and associates, pre-year end planning, foreign currency.

Author profile

Peter Collins FTI
Peter Collins, FTI, is a Partner at PwC with 25 years experience as a specialist in global tax, assisting foreign investors structuring their Australian investments and Australian corporates expanding offshore. He works with the firm’s global tax network to develop solutions for clients and is a member of the International Tax executive, which allows him to provide a unique global perspective. He is a consultant to Treasury in relation to tax reform in the areas of international tax and transfer pricing, including the MAAL/DPT and a member of the Treasury’s BEPS Tax Advisory Group. Peter was heavily involved in the rewrite of the Australian transfer pricing rules; he appeared before the Senate Estimates Committee to object to the retrospective application of those rules to US companies. He represented PwC before the Senate inquiry in relation to corporate tax avoidance by multinational companies. - Current at 01 November 2018
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This was presented at 16TH NATIONAL CONVETION: "A CAPITAL IDEA" .

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