ATO comments on the interaction of thin cap and TP provisions
January 16, 2008
Nick Houseman, Bill Yohana and Geoffrey Morris of PricewaterhouseCoopers Australia examine the implications of a new determination
The Australian Tax Office (ATO) has released a draft taxation determination, TD 2007/D20), which comments on how Australia’s thin capitalisation provisions (division 820 of the Income Tax Assessment Act 1997) interact with the transfer pricing provisions of the tax law (Division 13 of the Income Tax Assessment Act 1936 and the business profits article and associated enterprises article of a relevant double tax treaty).
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