Division 820 - Thin capitalisation rules  

Subdivision 820-F - Thin capitalisation rules for resident TC groups  

How this Division applies to a resident TC group

SECTION 820-565 [ARCHIVE]   820-565   Additional application of Subdivision 820-D to group that includes foreign-controlled Australian ADI  
Subdivision 820-D applies to a *resident TC group for an income year, as if the group were an *outward investing entity (ADI), if:

(a) the group is not an outward investing entity (ADI) for the income year; and

(b) the group includes at least one entity that is at the end of the income year both a *foreign controlled Australian entity and an *ADI; and

(c) the group includes at least one company that is at the end of the income year a 100% subsidiary of no entity covered by paragraph (b) of this section.


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