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Thin capitalisation, transfer pricing and debt deductions paper

Published on 18 May 10 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the interaction of the thin capitalisation rules with the domestic transfer pricing rules
  • can the applicability of a DTA containing an associated enterprises article affect the analysis?
  • what impact does parental affiliation have?
  • what impact do parental guarantees have?
  • what level of protection does the rule of thumb concession provide?

Author profiles:

James Nickless
James is a Partner • International tax and transfer pricing PricewaterhouseCoopers. Current at 01 December 2015 Click here to expand/collapse more articles by James Nickless.
 
Robert Pfeiffer
Robert works for PricewaterhouseCoopers. Current at 18 May 2010

Christian Holle ATI
Christian is a Partner with PricewaterhouseCoopers Current at 01 February 2015 Click here to expand/collapse more articles by Christian HOLLE.

This was presented at 3rd Annual Tax Forum.

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Author(s):  Howard ADAMS,  Glenn WILLIAMS

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