2010

Challenges to Funding Structures: Are you at risk?

Source: Victoria

Published Date: 4 May 2010

 
Recently the ATO has increased its focus on deductions arising from cross-border debt structures. This is evidenced by current audit activity with regard to interest paid to foreign affiliates, the ATOs review of section 25-90, its Taxpayer Alert 2009/09 and the release of TR2009/D6.

This event deconstructed some of the current thinking on the pricing of intra-group debt, the legality of the Commissioner's powers with regard to transfer pricing and discussed the practicalities of complying with the Commissioner's rule of thumb.

Certainty in the current tax funding market

Author(s): Braedon Clark CTA

The Commissioner's transfer pricing powers and thin capitalisation safe harbours

Author(s): Toby Knight CTA

Practical implications and observations from a transfer pricing perspective

Author(s): Chris Thomas , Garrick Robinson

Details

  • Published On:4 May 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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