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.
Copyright notice
© Australian Taxation Office for the Commonwealth of Australia
You are free to copy, adapt, modify, transmit and distribute material on this website as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).