Tax and Superannuation Laws Amendment (2014 Measures No. 4) Act 2014 (110 of 2014)
Schedule 1 Thin capitalisation
Part 7 Consequential amendments
Income Tax Assessment Act 1997
39 Section 820-205 (example)
Repeal the example, substitute:
Example: RJ Corporation is a company that is not an Australian entity. The average value of its Australian investments is $100 million.
The average value of its relevant excluded equity interests, associate entity debt, associate entity equity and non-debt liabilities is $5 million, $10 million, $5 million and $5 million respectively. Deducting those amounts from the result of step 1 leaves $75 million. Multiplying $75 million by 3/5 results in $45 million. As the company does not have any associate entity excess amount, the safe harbour debt amount is therefore $45 million.