Arm’s Length Conditions Override Actual Conditions – Transfer Pricing and Debt Equity Rules

Journal
Joseph, A.
Australia
International Transfer Pricing Journal 2019 (Volume 26), No. 6
FormatPDF
EUR
40
| USD
45
(VAT excl.)

Recently, the Australian Taxation Office released Taxation Determination 2019/10, containing further measures to prevent abusive tax behaviour in cross-border financing. This article discusses the implication of the determination, especially on the subject of arm’s length conditions and their widespread applicability in the taxation laws of Australia.