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  2010

Corporate Financing - Debt Which Does Not Generate Assessable Income

Source: Victoria

Published Date: 17 Nov 2010

 
The ATO in recent times has been exploring ways to challenge interest deductions on borrowings of Australian resident companies, particularly where the borrowings are from related foreign parties. Many of these issues are currently under investigation by the ATO during the course of reviews and audits. An important development has been the finalisation of Taxation Ruling 2010/7 on the interaction of the transfer pricing and thin capitalisation rules.

This event analysed these issues in the context of debt which funds:

  • distributions to owners (including dividends under new section 254T of the Corporations Act)
  • Section 23AJ and foreign branch investments
  • refinancing of group debt.

Debt which does not generate assessable income

Author(s): Cameron Rider FTI
Materials from this session:

Details

  • Published On:17 Nov 2010
  • Took place at:RACV Club, Melbourne

The material is copyright. Apart any fair dealing for the purpose of private study,

research critisism or review, as permitted under the copyright Act, no part may be rerpoduced 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.

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

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

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2010

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