INCOME TAX ASSESSMENT ACT 1997 [ARCHIVE]

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 820 - Thin capitalisation rules  

Subdivision 820-F - Thin capitalisation rules for resident TC groups  

How this Division applies to a resident TC group

SECTION 820-565 [ARCHIVE]   820-565   Additional application of Subdivision 820-D to group that includes foreign-controlled Australian ADI  
Subdivision 820-D applies to a *resident TC group for an income year, as if the group were an *outward investing entity (ADI), if:


(a) the group is not an outward investing entity (ADI) for the income year; and


(b) the group includes at least one entity that is at the end of the income year both a *foreign controlled Australian entity and an *ADI; and


(c) the group includes at least one company that is at the end of the income year a 100% subsidiary of no entity covered by paragraph (b) of this section.




This information is provided by CCH Australia Limited Link opens in new window. View the disclaimer and notice of copyright.