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

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Publication date: 27 Oct 20 | Source: NATIONAL DIVISION, THE TAX INSTITUTE

This video covers:

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

Author profiles

Shahzeb Panhwar
Shahzeb Panhwar is an Assistant Commissioner in the Public Groups and International area of the ATO and heads up the International Tax Structuring practice. In this role Shaz has responsibility for related party financing, thin capitalisation and thin capitalisation. Previously, Shaz’s roles have included overseeing PGI’s disputes strategy, the ATO’s international engagement programs and management of the Docklands audit teams. - Current at 16 July 2021
Cindy Perryman ATI
Cindy is a corporate tax partner at Deloitte in Melbourne and specialises in advising on financing issues related to inbound and outbound investments. Cindy has a focus on thin capitalisation and in particular the arm’s length debt test, having been involved in drafting the public guidance on the test when formerly at the ATO. - Current at 17 November 2020
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