Australia’s new transfer pricing laws overlap the thin cap rules: challenges for taxpayers
By Jock McCormack The overlap of Australia’s new transfer pricing laws with the thin capitalisation rules is causing challenges and likely duplication of analysis for taxpayers — particularly for the arm’s-length amount-of-debt test. Australia legislated comprehensive new transfer pricing laws in 2012 and 2013. These laws were passed in two instalments: Subdivision 815-A, dealing with assessing […]