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is unworkable in practice, there are other effective ways of preventing excessive debt deductions, but without the attendant uncertainty and compliance costs. 2. for the purposes of the transfer pricing provisions, is inconsistent with the clearly stated policy objective to minimise compliance costs as stated in paragraph 11.11 of the EM. 3. for purposes of application of the transfer pricing provisions as proposed in the Ruling rather than applying the transfer pricing provisions on the basis of the actual debt that a taxpayer has diverges from accepted practice in the interpretation of the arm's length principle as set out in the OECD's 'Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ', in particular paragraph 1.36. 4. which is notional rather than the actual amount appears to be a key element of the ATO's position so should be clearly stated. 5. requires practical guidance from the ATO on how this should be done. 6. imposes an additional compliance burden so the ATO should implement administrative practice(s) to mitigate this burden.