Thin capitalisation and transfer pricing
01 December 2010
 |
| Ian Farmer |
On October 27, the Australian Commissioner of Taxation's issued the long-awaited Taxation Ruling (TR 2010/7) on how the thin capitalisation provisions interact with the transfer pricing provisions. TR 2010/7 formalises and expands on the views that the Australian Taxation Office (ATO) had put forward in its previous draft ruling, TR 2009/D6.
Key issues
The transfer pricing provisions apply independently of Australia's thin capitalisation provisions in determining the allowable deduction for a taxpayer's related party debt. The transfer pricing provisions are to...
This article is available to subscribers and current trialists of International Tax Review only. Please log in or subscribe for access to the rest of the article.
Alternatively take a free trial, giving you 7 days of access.
Subscribe now
This article is available to subscribers only. To read the rest of this article please subscrbe.
Subscribe
Free trial
This article is available to trialists and subscribers only. Please take a free 7 day trial to read the rest of the article.
Free trial