This paper covers:
- financing deductions - an update
- debt equity issues in the context of cross border financing
- effectively non-contingent obligations: TR 2008/3 - the last word?
- Section 974-80 - where to now?
- Australia's transfer pricing regime - interaction between our treaties and Division 13
- transfer pricing and thin capitalisation - is there a safety in safe harbours? TD 2008/20, TD 2007/D20 and ATO Discussion Paper 08/7290
- the relevance of foreign law consequences to the domestic law.