Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 815 - Cross-border transfer pricing  

Subdivision 815-A - Treaty-equivalent cross-border transfer pricing rules  

Operative provisions

SECTION 815-25   Modified transfer pricing benefit for thin capitalisation  

815-25(1)  
This section modifies the * transfer pricing benefit an entity gets, or apart from this section would get, in an income year if:


(a) Division 820 (about thin capitalisation) applies to the entity for the income year; and


(b) the transfer pricing benefit relates to profits, or a shortfall of profits, referable to costs that are * debt deductions of the entity for the income year.

815-25(2)  
If working out what those costs might have been, or might be expected to be, involves applying a rate to a * debt interest :


(a) work out the rate by applying section 815-15 , having regard to section 815-20 ; but


(b) apply the rate to the debt interest the entity actually issued.

Note:

Division 820 may apply to further reduce debt deductions.


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