Income Tax Assessment Act 1997
CHAPTER 4
-
INTERNATIONAL ASPECTS OF INCOME TAX
PART 4-5
-
GENERAL
Division 820
-
Thin capitalisation rules
Guide to Division 820
SECTION 820-10
820-10
Map of Division
The following table sets out a map of this Division.
View history note
Hide history noteThe following table sets out a map of this Division.
| Map of Division | |||
| Item | This Subdivision: | sets out: | |
| 1A | Subdivision 820-AA | (a) | how all or a part of the debt deductions claimed by an entity covered by the Subdivision may be disallowed under one of three tests (the fixed ratio test, the group ratio test or the third party debt test); and |
| (b) | how the entity can choose to apply which one of these tests applies; and | ||
| (c) | where the fixed ratio test applies, whether the entity can claim a special deduction in respect of amounts previously disallowed under the fixed ratio test. | ||
| 1 | Subdivision 820-B or 820-C | (a) | the meaning of maximum allowable debt for the Subdivision; and |
| (b) | how an entity covered by the Subdivision would have all or a part of its debt deductions disallowed if the maximum allowable debt is exceeded; and | ||
| (c) | the application of these rules in relation to a part of an income year. | ||
| 2 | Subdivision 820-D or 820-E | (a) | the meaning of minimum capital amount for the Subdivision; and |
| (b) | how an entity covered by the Subdivision would have all or a part of its debt deductions disallowed if the minimum capital amount is not reached; and | ||
| (c) | the application of these rules in relation to a part of an income year. | ||
| 2A | Subdivision 820-EAA | how all or a part of the debt deductions claimed by an entity covered by Subdivision 820-AA , 820-B or 820-C may be disallowed in relation to: | |
| (a) | debt deductions in relation to the acquisition of CGT assets, or legal or equitable obligations, from associate pairs of the acquirer; or | ||
| (b) | debt deductions in relation to a financial arrangement that is entered into by an entity to fund etc. certain payments or distributions to one or more associate pairs of the entity. | ||
| 2B | Subdivision 820-EAB | (a) | concepts concerning third party debt; and |
| (b) | concepts that are relevant to entities that choose to apply the third party debt test. | ||
| 3 | (Repealed by No 101 of 2006 ) | ||
| 3A | Subdivision 820-FA | how this Division applies to a consolidated group or MEC group. | |
| 3B | Subdivision 820-FB | special rules for grouping foreign bank branches with a consolidated group, MEC group or single Australian resident company. | |
| 4 | Subdivision 820-G | the methods of calculating the average value of a matter for the purposes of this Division. | |
| 5 | Subdivision 820-H | the rules for determining: | |
| (a) | whether or not an Australian entity controls a foreign entity (for the purposes of determining whether or not Subdivision 820-B or 820-D applies to that Australian entity); and | ||
| (b) | whether or not an Australian entity is controlled by a foreign entity (for the purposes of determining whether or not Subdivision 820-C applies to that Australian entity). | ||
| 5A | Subdivision 820-HA | the meaning of controlled foreign entity debt and controlled foreign entity equity for the purposes of this Division. | |
| 6 | Subdivision 820-I | the meaning of various concepts about associate entity for the purposes of this Division. | |
| 7 | Subdivision 820-J | the meaning of equity interests in trusts and partnerships for the purposes of this Division. | |
| 7A | Subdivision 820-JA | worldwide debt and equity concepts. | |
| 8 | Subdivision 820-K | the meaning of zero-capital amount for the purposes of this Division. | |
| 8A | Subdivision 820-KA | the meaning of cost-free debt capital, and excluded equity interest, for the purposes of this Division. | |
| 9 | Subdivision 820-L | special record keeping requirements for the purposes of this Division. |
This information is provided by CCH Australia Limited Link opens in new window. View the disclaimer and notice of copyright.