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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

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Christian HOLLE
Christian is a partner in the International Tax Services group of PwC in Sydney and part of PricewaterhouseCoopers' Global Real Estate group. He specialises in cross-border acquisition and funding structuring and advises a number of Australian funds and corporates with regard to real estate investments in Europe, the US and Asia. He also advises overseas clients, in particular from Europe and Asia, on investments in Australian real estate.
Current at 1 August 2007
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Robert PFEIFFER

This was presented at 3rd Annual Tax Forum .

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Individual sessions


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Structuring a professional practice

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Update on deductibility under section 8.1

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Role of accounting standards in TOFA

Author(s):  Tracey RENS

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Implementing TOFA in a large corporation

Author(s):  Mark BRADFORD,  Gavin MARJORAM

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Tax administration without borders

Author(s):  Howard ADAMS,  Glenn WILLIAMS

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