Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 820 - Thin capitalisation rules  

Subdivision 820-EAA - Debt deduction limitation rules for debt deduction creation (all relevant entities)  

SECTION 820-423   What this Subdivision is about  


This Subdivision sets out debt deduction limitation rules that apply to entities that are dealt with in rules set out in Subdivisions 820-AA , 820-B , 820-C , 820-D or 820-E . These rules deal with:

  • (a) debt deductions in relation to the acquisition of CGT assets, or legal or equitable obligations, from associate pairs of the acquirer; and
  • (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.
  • The rules in this Subdivision are applied before the rules set out in Subdivisions 820-AA , 820-B and 820-C . If a debt deduction of an entity is disallowed under this Subdivision, the debt deduction is disregarded for the purpose of applying those other Subdivisions (see section 820-31 ).


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