OrbitaxFinal Ruling on interaction of thin capitalization and transfer pricing rules issued
|Approved Changes|Australia
The Australian Taxation Office (ATO) released final ruling TR 2010/7 on the interaction between the transfer pricing and thin capitalization provisions. The ruling was previously released in draft as TR 2009/D6, and was not substantially changed from the earlier draft ruling.
Briefly, the ATO expresses a view that the transfer pricing provisions may apply to a loan that sat…
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