Interaction of Div 820 ITAA 1997 and transfer pricing provisions re debt deductions - TR 2009/D6
17 Dec 2009
This draft Taxation Ruling was released on 16 December 2009 for public comment by 12 February 2010. Its full title is "Income tax: the interaction of Division 820 of the Income Tax Assessment Act 1997 and the transfer pricing provisions in relation to costs that may become debt deductions, for example, interest and guarantee fees".
As a result, draft Taxation Determination TD 2007/D20 (Income tax: where there is no excess debt under Division 820 of ITAA 1997, can the transfer pricing provisions apply to adjust the pricing of costs that may become debt deductions, for example, interest and guarantee fees?) is withdrawn with effect from the same day.
For a copy of TR 2009/D6, go here
For a copy of TD 2007/D20W, go here