INTERNATIONAL ASPECTS OF INCOME TAX
Thin capitalisation rules
Thin capitalisation rules for resident TC groups
SECTION 820-450 (ARCHIVE)
What this Subdivision is about
This Subdivision sets out the thin capitalisation rules that apply to a group of entities (called a resident TC group). If those rules apply to the group, the rest of the Division does not apply separately to the entities in the group.
This Subdivision tells you:
how to construct a resident TC group; and
how to classify the group (in terms of which Subdivision of this Division to apply); and
how to apply this Division to the group (including how the application is modified).