2024

Recharacterising Debt as Equity under transfer pricing/Pt IVA

Published Date: 13 Jun 2024

 

One of the most contentious issues facing foreign investors is the sizing and pricing of investor debt. This session considered when and how the Commissioner may recharacterise debt as equity. Topics covered included:

  • The relevance of transfer pricing rules to the choice between debt and equity
  • The effect of proposed changes to protections under the thin capitalisation rules; and
  • Is there scope for Part IVA to apply?

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Individual Session

Author(s): Eugene Wheelahan FTI , Mia Clarebrough

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2024

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