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On 29 July 2008, the Taxation Institute lodged a submission with the ATO on the ATO’s paper "Intra-group finance guarantees and loans - Application of Australia’s transfer pricing and thin capitalisation rules". The Taxation Institute says that "there appears to be a significant gulf between the position in the Discussion paper and both existing Australian tax law and financial market practice.  This disparity is significant, given both the deviation of the ATO’s proposed treatment of financial transactions from arm’s-length principles and its potential for retrospective application."

For a copy of the submission, go here

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