Australian tax office issues guidance on thin cap arm’s length debt test

The Australian Taxation Office on April 5 issued a draft taxation ruling (Tr 2019/2) addressing key technical issues that may arise in determining an entity’s arm’s length debt amount for purposes of Australia’s thin cap rules.

The ruling also provides interpretative guidance relating to the record-keeping requirements in section 820-980.

The ATO seeks public comment on its draft guidance by May 31.


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