ATO May Apply Arm’s-Length Rate To Interest Despite Thin Cap Safe Harbor

The Australian Taxation Office in two December draft statements that it may apply the arm’s-length interest rate to adjust the pricing of related-party debt that falls within the nation’s thin capitalization safe harbor, and that related-party taxpayers may adopt the interest rate paid by their parent company for such debt. Enjoying this article? To continue reading you need to take out a FREE trial to the Transfer Pricing Library.




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