Taxation Laws Amendment Act (No. 4) 2002 (53 of 2002)

Schedule 1   Thin capitalisation

Part 1   Amendments

Income Tax Assessment Act 1997

6   At the end of section 820-37

Add:

Foreign entity - debt interest issued by an Australian entity

(2) If a *foreign entity holds a *debt interest that:

(a) was *issued by an *Australian entity; and

(b) is *on issue;

this subsection covers the interest to the extent to which the interest is not attributable to any *foreign permanent establishments of the Australian entity.

Foreign entity - equity interest in an Australian entity

(3) If a *foreign entity holds an *equity interest in an *Australian entity, this subsection covers the interest to the extent to which the interest is not attributable to any *foreign permanent establishments of the Australian entity.


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