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Australian legislative responses to the BEPs report - The changes so far and what you should be thinking about! paper


This paper covers:

  • thin capitalisation changes - safe harbour and worldwide gearing
  • the arm’s length debt test - status update
  • refinancing to manage thin capitalisation changes - the tips and traps!
  • the interface of thin capitalisation, s25-90 and s23AJ and the status of NANE income
  • transparency changes
  • the repeal of s25-90 – what apportionment, allocation or tracing issues will arise.

Author profiles

Ernest Chang FTI
Photo of author, Ernest Chang Ernest Chang, FTI, is a Partner in Pricewaterhouse Cooper's International and Financial Services Tax practice in Sydney and is the Financial Services Tax Leader in Australia. Ernie has over 20 years experience advising on primarily corporate and international taxation. Prior to recently joining PwC, he was a Partner for over 15 years at another premium tax practice. He advises on a wide range of corporate tax matters including capital management, international mergers and acquisitions, due diligence investigations, foreign source income, corporate restructuring, schemes of arrangement, management buyouts, overseas investment in Australia, employee share acquisition schemes and privatisation. - Current at 12 July 2013
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Rosalind MYINT
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Arash Azimi
Arash is a Senior Consultant at PwC. - Current at 13 February 2013
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This was presented at International Masterclass .

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Individual sessions

Legislative changes to the transfer pricing rules - The practical implications

Author(s):  Tony Gorgas

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