Australia’s new transfer pricing laws overlap the thin cap rules: new challenges for taxpayers
The overlap of Australia’s new transfer pricing laws with the thin capitalization 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[i] and 2013.[ii] These laws were passed in two installments: Subdivision 815-A, dealing with… – Continue reading