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?
Current at 04 January 2011
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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 Current at 11 August 2007
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Current at 25 September 2010