ITAA 1936 s 13

Certain cross-border Prepaid Forward Purchase Agreements

Arrangements involving interposed offshore entities to avoid interest withholding tax

Compendium

Income tax: where a taxpayer has supplied or acquired property under an international agreement and that gives rise to a debt interest or an equity interest as defined for the purposes of Division 974 of the Income Tax Assessment Act 1997, does Division 974 bear upon the characterisation to be adopted for the purposes of the application of Division 13 of Part III of the Income Tax Assessment Act 1936 to the transaction?

Income tax: when is the shortfall interest charge incurred for the purposes of paragraph 25-5(1)(c) of the Income Tax Assessment Act 1997?

Income tax: are the capital support payments described in this Draft Determination deductible under section 8-1, section 40-880, subsection 230-15(2) or subsection 230-15(3) of the Income Tax Assessment Act 1997?

Income tax: thin capitalisation - applying the arm's length debt test

Income tax: transfer pricing - the application of section 815-130 of the Income Tax Assessment Act 1997

Income tax: transfer pricing: documentation requirements

Income tax: transfer pricing: application for advance pricing agreements - bilateral and unilateral advance pricing agreement procedures

Referral of Work to International Strategy and Operations

Transfer Pricing Review Work

Income tax: does Division 13 of the Income Tax Assessment Act 1936 apply to impute interest income to an Australian company which makes an interest-free loan to a non-resident subsidiary to enable this subsidiary to guarantee a third party loan to another non-resident subsidiary?

Withdrawal - Does Division 13 of the Income Tax Assessment Act 1936 apply to impute interest income to an Australian company which makes an interest-free loan to a non-resident subsidiary to enable this subsidiary to guarantee a third party loan to another non-resident subsidiary?

Income tax: international transfer pricing - penalty tax guidelines

Transfer Pricing