Income Tax Assessment Act 1997



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  

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.

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.


Division 820 may apply to further reduce debt deductions.


Disclaimer and notice of copyright applicable to materials provided by CCH Australia Limited

CCH Australia Limited ("CCH") believes that all information which it has provided in this site is accurate and reliable, but gives no warranty of accuracy or reliability of such information to the reader or any third party. The information provided by CCH is not legal or professional advice. To the extent permitted by law, no responsibility for damages or loss arising in any way out of or in connection with or incidental to any errors or omissions in any information provided is accepted by CCH or by persons involved in the preparation and provision of the information, whether arising from negligence or otherwise, from the use of or results obtained from information supplied by CCH.

The information provided by CCH includes history notes and other value-added features which are subject to CCH copyright. No CCH material may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way, except that you may download one copy for your personal use only, provided you keep intact all copyright and other proprietary notices. In particular, the reproduction of any part of the information for sale or incorporation in any product intended for sale is prohibited without CCH's prior consent.