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

Anthony Clemens

Tony is a Senior Tax Partner of PricewaterhouseCoopers, specialising in international taxation. He has a role of advising many of the clients of the firm with international tax related transaction. He has been a partner for 24 years and specialises in cross border transactions and international financing. - Current at 22 November 2005

More by Tony CLEMENS

• An update on changes to Australia’s international tax system - Inbound investment paper - 18-May-2010
• Australian taxation aspects of investment in Asia paper - 15-February-2006
• Australian taxation aspects of major funding transactions - Part 2 - 01-August-2005
• Australian taxation aspects of major funding transactions - Part 1 - 01-June-2005
• Australian taxation aspects of major funding transactions paper - 18-March-2005
• International aspects of CGT - a collection of current issues - 12-November-1998
• Outbound investments - listed countries seminar paper - 14-June-1996

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