shopping_cart

Your shopping cart is empty

Safe harbour or “rule of thumb”

Published on 01 Feb 10 by "THE TAX SPECIALIST" JOURNAL ARTICLE

The ATO is taking an expansive view of its transfer pricing powers. The release of a new draft ruling on the interaction of the thin capitalisation and transfer pricing rules has implications for all taxpayers with loans or guarantees with cross-border related parties. Taxpayers who have sought the refuge of the thin capitalisation “safe harbour” will still need to calculate a hypothetical gearing structure for a financially independent entity in the position of the taxpayer. This article explores the ATO’s position and the implications it has for non-residents funding their Australian businesses.

Author profile:

Author Photo - Paul KORGANOW
Paul KORGANOW
Current at 07 December 2011 Click here to expand/collapse more articles by Paul KORGANOW.
 

 

Copyright Statement
click to expand/collapse