Deductibility of support payments made by a parent entity to its subsidiary - TD 2013/D3
24 Apr 2013
On 24 April 2013, the ATO released for public comment by 22 May 2013 draft Taxation Determination TD 2013/D3 entitled "Income tax: are support payments made by a parent entity to its subsidiary deductible under section 8-1 or section 40-880 of the Income Tax Assessment Act 1997?"
The answer given to the question posed is "No. Support payments are capital in nature for the purposes of paragraph 8-1(2)(a) of the Income Tax Assessment Act 1997...Furthermore, such payments are included in the cost base and reduced cost base of the parent's investment in the subsidiary and are therefore not deductible under s 40-880."