Transfer pricing, thin capitalization and debt-equity rules

Journal
Joseph, A.
International Transfer Pricing Journal 2008 (Volume 15), No. 6
FormatPDF
EUR
40
| USD
45
(VAT excl.)

After presenting the background on thin capitalization rules and debt-equity rules in Australia, this article discusses draft determinations dealing with the interaction between thin capitalization and transfer pricing rules, as well as the interaction between statutory rules on debt-equity classification and transfer pricing rules. A Discussion Paper on intra-group finance guarantees and loans is also considered.