INCOME TAX ASSESSMENT ACT 1997 [ARCHIVE]
CHAPTER 4
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INTERNATIONAL ASPECTS OF INCOME TAX
PART 4-5
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GENERAL
Division 820
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Thin capitalisation rules
Subdivision 820-F
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Thin capitalisation rules for resident TC groups
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.
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.
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