Thin capitalisation and arm’s length debt test: KPMG’s submission

Tim Keeling, Jenny Wong and Matthew McRae discuss key points on the Australian Taxation Office’s Draft Taxation Ruling 2019/D2.

With the Labor policies on thin capitalisation under review following the federal election (and their proposals of only having a single worldwide gearing test and removing the safe harbour and the arm’s length test on the cards before the election), it is now business as usual in the application of the thin capitalisation provisions.This article focuses on our submission points on the Australian Taxation Office’s Draft Taxation Ruling TR 2019/D2 Income tax: thin capitalisation – the arm’...

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Authors: Tim Keeling, Jenny Wong,

Published Date: 05 June 2019