International tax & business 2012

The good and bad news for in-bound and out-bound investors

Source: Taxation In Australia Journal Article

Published Date: 1 Oct 2012

 

The federal government’s Business Tax Working Group is considering possible changes to the thin capitalisation regime as part of its review of the corporate tax regime. Each of the potential changes to the thin capitalisation rules being considered by the working group would result in reduced tax deductibility of interest
and, therefore, higher tax bills for those who exceed thin capitalisation debt limits. However, a growing number of companies have increased their safe harbour debt amount calculations and the tax deductibility of their debt by exercising the option to include the value of certain assets not currently recognised on their accounting balance sheets.

This article examines the proposed changes and concludes that, although they will translate into larger tax bills for those breaching the current limits or the proposed lower limits, planning ahead and valuing intangible assets for thin capitalisation purposes can increase safe harbour debt amounts significantly in many cases.

Author(s)

Sorry, this is subscriber only content.

To gain access to this material and much more - Subscribe Now.

(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).

Already a Subscriber? Login now

Details

The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))

("TTI")

The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.

Tags

International tax & business 2012

Share this page