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Legislation
ATO documents that consider ITAA 1997 s 820
43 documents
Goods and services tax: reduced credit acquisitions
Diverted profits tax
ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions
ATO compliance approach to the arm's length debt test
Restructures and the thin capitalisation and debt deduction creation rules - ATO compliance approach
Economic advice and the Economist Practice
Compendium
Income tax: is an amount that is a cost in relation to a debt interest covered by paragraph 820-40(1)(a) of the Income Tax Assessment Act 1997 (ITAA 1997) deductible under section 25-90 of the ITAA 1997 (or, alternatively, under subsection 230-15(3) of the ITAA 1997) where that amount is incurred in earning income that meets the requirements of both section 23AH of the Income Tax Assessment Act 1936 and section 768-5 of the ITAA 1997?
Compendium
Income tax: thin capitalisation - valuation of debt capital for the purposes of Division 820
Compendium
Income tax: Thin Capitalisation - Definition of assets and liabilities for the purposes of Division 820.
Income tax: branch funding for multinational banks
Public rulings
Income tax: the interaction of Division 820 of the Income Tax Assessment Act 1997 and the transfer pricing provisions
Compendium
Income tax: thin capitalisation - the arm's length debt test
Factors to consider when determining the amount of your inbound, cross-border related party financing arrangement - ATO compliance approach
Thin capitalisation - Incorrect calculation of the value of 'debt capital' treated wholly or partly as equity for accounting purposes
Arrangements involving interposed offshore entities to avoid interest withholding tax