Income Tax Assessment Act 1997
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Hide history noteSECTION 815-25 Modified transfer pricing benefit for thin capitalisation 815-25(1)
This section modifies the * transfer pricing benefit an entity gets, or apart from this section would get, in an income year if:
(a) Division 820 (about thin capitalisation) applies to the entity for the income year; and
(b) the transfer pricing benefit relates to profits, or a shortfall of profits, referable to costs that are * debt deductions of the entity for the income year.
815-25(2)
If working out what those costs might have been, or might be expected to be, involves applying a rate to a * debt interest :
(a) work out the rate by applying section 815-15 , having regard to section 815-20 ; but
(b) apply the rate to the debt interest the entity actually issued.
Note:
Division 820 may apply to further reduce debt deductions.
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