Thin capitalization and transfer pricing

Journal
Joseph, A.
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2008 (Volume 10), No. 1
PriceUSD 45

Thin capitalization and transfer pricing rules have become increasingly topical in the current globalized economic environment and are causing anxiety to tax authorities and taxpayers alike. Australia is no different, and a recent draft taxation determination of the Australian Taxation Office has set the tax community aflutter. This article considers the draft, as well as other thin capitalization rules in a transfer pricing context.