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Legislation
ATO documents that consider ITAA 1997 s 820
43 documents
Debt deduction: interest paid on convertible notes
Thin capitalisation rules: risk-weighted assets - non-banking members
Thin capitalisation rules: Tier 1 prudential capital deductions - non-banking members
Definition of 'public company': company controlled by a Government - tracing an interest held through a chain of subsidiaries
Diverted profits tax
ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions
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
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?
Income tax: thin capitalisation - valuation of debt capital for the purposes of Division 820
Income tax: Thin Capitalisation - Definition of assets and liabilities for the purposes of Division 820
Income tax: branch funding for multinational banks
Income tax: the interaction of Division 820 of the Income Tax Assessment Act 1997 and the transfer pricing provisions in relation to costs that may become debt deductions, for example, interest and guarantee fees
Income tax: thin capitalisation - the arm's length debt test
Thin Capitalisation - Australian equivalents to International Financial Reporting Standards ('AIFRS') - Transitional Provision
Income tax: how do the transitional measures in the Corporations Act 2001 ('Corporations Act') impact upon the definition of a financial entity for the purposes of Division 820 of the Income Tax Assessment Act 1997 ('ITAA 1997')?
Income tax: where there is no excess debt under Division 820 of the Income Tax Assessment Act 1997 can the transfer pricing provisions apply to adjust the pricing of costs that may become debt deductions, for example, interest and guarantee fees?
Notice of Withdrawal - Income tax: where there is no excess debt under Division 820 of the Income Tax Assessment Act 1997, can the transfer pricing provisions apply to adjust the pricing of costs that may become debt deductions, for example, interest and guarantee fees?
Income tax: thin capitalisation - applying the arm's length debt test