Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 820 - Thin capitalisation rules  

Subdivision 820-JA - Worldwide debt and equity concepts  

Operative provisions

SECTION 820-932   Worldwide debt and worldwide equity  


Worldwide debt

820-932(1)    
An entity ' s worldwide debt at a particular time, means the total of the following amounts:


(a) all the *debt interests issued by the entity:


(i) to entities other than any *Australian controlled foreign entities (the controlled entities ) of which the entity is an *Australian controller at that time; and

(ii) that are still *on issue at that time;


(b) all the debt interests issued by the controlled entities:


(i) to entities other than the entity or other controlled entities; and

(ii) that are still on issue at that time.


Worldwide equity

820-932(2)    
An entity ' s worldwide equity at a particular time, means the total of the following amounts:


(a) all the *equity capital of the entity as at that time, but worked out disregarding *equity interests in the entity held at that time by *Australian controlled foreign entities (the controlled entities ) of which the entity is an *Australian controller at that time;


(b) all the equity capital of the controlled entities as at that time, but worked out disregarding equity interests in the controlled entities held at that time by:


(i) the entity; or

(ii) other controlled entities.


 

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