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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 05 November 2010
Click here to expand/collapse more articles by James Nickless.
Christian Holle ATI
Christian is a Partner with PricewaterhouseCoopers - Current at 19 May 2017
Click here to expand/collapse more articles by Christian HOLLE.
Robert Pfeiffer
Robert works for PricewaterhouseCoopers. - Current at 10 January 2013

 

This was presented at 3rd Annual Tax Forum .

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Role of accounting standards in TOFA

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Implementing TOFA in a large corporation

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Tax administration without borders

Author(s):  Howard ADAMS,  Glenn WILLIAMS

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