Cross border financing

Can the transfer pricing rules re-characterise your financing arrangement as debt or equity?

The short answer is yes – following the release of the latest ATO final ruling TD 2019/10 Income tax: can the debt and equity rules in Division 974 of the Income Tax Assessment Act 1997 limit the operation of the transfer pricing rules in Subdivision 815-B of the Income Tax Assessment Act 1997.  If you have cross border financing, you should consider the Australian Taxation Office (ATO)’s latest interpretive guidance. TD 2019/10 is in substance unchanged from the draft TD 2018/D6 (except...

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Authors: Jenny Wong

Published Date: 12 July 2019