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Thin capitalisation and transfer pricing paper

Published on 09 Feb 10 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

In November 2007, the ATO released Draft Tax Determination TD 2007/D20. The draft stated: "..the existence of a safe harbour debt amount for the purposes of Division 820 [Thin Cap] does not prevent the Commissioner from determining an appropriate arm's length cost for all of the debt funding ..". This was followed by the release of a Discussion Paper on "Intra-group finance guarantees and loans" in June 2008, and a number of selected references in 2009 speeches by the Commissioner and other ATO officers.

This paper provides an up-to-date report on subsequent progress, including:

  • a summary of the latest ATO position
  • Division 13 and its interface with other arm's length rules
  • the arm's length principle
  • the tax policy perspective.

Author profile:

Richard SHADDICK
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This was presented at Current Corporate Tax Issues .

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The international tax interface

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