ATO ruling causes controversy over arm’s-length interest
November 03, 2010
Sophie Ashley - TPW
The Australian Tax Office (ATO) has published the final version of a controversial Taxation Ruling (TR 2010/7) about the interaction between the country’s transfer pricing and thin capitalisation rules.
The report, to a large extent, repeats the views expressed in the draft ruling, released earlier in the year, on topics such as debt deductions, parental affiliation and the credit quality of a subsidiary. Advisers are concerned that the ruling will mean less certainty for taxpayers and a greater risk of double taxation.
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