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2020 National Infrastructure Conference - Part 3: Thin capitalisation rules – How arm’s length is arm’s length?

Published on 27 Oct 2020 | Took place at Online, National

With the ATO’s increasing scrutiny on debt deductions and the interaction with the thin capitalisation provisions, this session covered:

  • the ATO’s compliance approach to the arm’s length debt test outlined in PCG 2020/7
  • the ATO’s new risk assessment framework
  • the role of credit ratings
  • interaction with the transfer pricing regime
  • practical experience in managing the ATO’s risk assessment framework.

Individual sessions

Thin capitalisation rules - How arm’s length is arm’s length?

Author(s):  Shahzeb Panhwar,  Cindy Perryman

This presentation covers:

  • history of ALDT use
  • availability of guidance
  • history of disputes
  • availability of comfort?
  • two headed monster – TR 2020/4 and PCG 2020/7.
Materials from this session: