Income Tax Assessment Act 1997



Division 820 - Thin capitalisation rules  

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

SECTION 820-890   What is controlled foreign entity equity ?  

The relevant entity's controlled foreign entity equity at a particular time during the relevant period is the total value of:

(a) all the *equity interests that the entity holds, at that time, in entities that are controlled entities of the relevant entity at that time; and

(b) all the *debt interests *on issue and held by the entity at that time that satisfy both of the following:

(i) the interests were *issued by entities that are controlled entities of the relevant entity at that time;

(ii) none of the interests gives rise to any 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 an *equity interest in, or 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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