Rethinking the Interest Deduction Rules in Light of the Chevron Australia Case

Journal
Australia; International
Bulletin for International Taxation 2018 (Volume 72), No. 9
Based on the case of Chevron Australia (2017), this article argues that excessive debt loading and the transfer mispricing of financial transactions could be addressed by a limited formulary apportionment rule for debt deductions. The article also offers insights into the likely implications of the global adoption of such a model.