Income Tax Assessment Act 1997



Division 820 - Thin capitalisation rules  

Subdivision 820-HA - Controlled foreign entity debt and controlled foreign entity equity  

SECTION 820-885   What is controlled foreign entity debt ?  

The relevant entity's controlled foreign entity debt at a particular time during the relevant period is the total value of all the *debt interests held by the relevant entity at that time that satisfy all of the following:

(a) the interests are *on issue at that time;

(b) each of the interests was *issued by an entity that is a controlled entity of the relevant entity at that time;

(c) each of the interests gives rise to a cost, at any time, that is covered by paragraph 820-40(1)(a) .

For the purposes of subsection (1), take into account the value of a *debt interest issued by a controlled entity of the relevant entity only to the extent that the interest is not attributable to any of the following assets that are held by the controlled entity throughout the relevant period:

(a) assets attributable to the controlled entity's *Australian permanent establishments;

(b) other assets that are held by the controlled entity for the purposes of producing assessable income of the controlled entity.


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