Corporate Financing – Debt Which Does Not Generate Assessable Income
Published on 17 Nov 2010
| Took place at RACV Club, Melbourne
The ATO in recent times has been exploring ways to challenge interest deductions on borrowings of Australian
resident companies, particularly where the borrowings are from related foreign parties. Many of these issues are currently under investigation by the ATO during the course of reviews and audits. An important development has been the finalisation of Taxation Ruling 2010/7 on the interaction of the transfer pricing and thin capitalisation rules.
This event analysed these issues in the context of debt which funds:
- distributions to owners (including dividends under new section 254T of the Corporations Act)
- Section 23AJ and foreign branch investments
- refinancing of group debt.