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Inbound Thin Capitalisation Rules

Published on 03 Apr 01 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper considers the application of the proposed thin capitalisation rules to Australian entities that are foreign controlled and foreign entities that operate in Australia. The paper focuses on the provisions contained in Subdivision 820-C which applies to inward investing entities that are not approved deposit-taking institutions (ADIs). Part 2 of this paper outlines the rules as they apply to inward investing entities. Part 3 highlights various issues for inward investing entities some of which are currently being addressed by the Government.

Author profile:

Tony CLEMENS
Tony is a Partner in the Mergers and Acquisitions/International Tax Services Group in Sydney and has been with PricewaterhouseCoopers since 1978. He was admitted as a Partner of the Taxation Division in 1986. Since 1988 he has been a Lead Partner of Australian Tax, Mergers and Acquisitions and International Group. He is currently a member of the firm's Board of Partners. Tony advises many Australian multinationals on their international business transactions. He is regularly included as an adviser on the largest transactions in Australia each year. Tony has been nominated by the International Tax Review as one of Australia's leading tax advisers for many years.
Current at 22 November 2005 Current at 23 October 2007 Click here to expand/collapse more articles by Tony CLEMENS.
 

 

This was presented at Thin Capitalisation and Debt/Equity Rules .

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