Transfer pricing and thin capitalisation

Amid the flurry of pre-Christmas desk clearing in the ATO was one long running and important matter of great concern to corporate Australia. The ATO has replaced its 2007 draft determination on the relationship of the thin capitalisation and transfer pricing rules with a draft ruling, as well as releasing a draft practice statement and two opinions it has obtained from counsel on the technical issues. Though the matter is not yet settled, the ATO position has firmed up on the middle ground in terms of its previous consideration of the issue. For our full Tax Brief - click here