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Thin capitalisation, transfer pricing and debt deductions paper

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Published on 18 May 10 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the interaction of the thin capitalisation rules with the domestic transfer pricing rules
  • can the applicability of a DTA containing an associated enterprises article affect the analysis?
  • what impact does parental affiliation have?
  • what impact do parental guarantees have?
  • what level of protection does the rule of thumb concession provide?

Author profiles

Christian Holle
Christian is a Partner with PricewaterhouseCoopers - Current at 01 February 2015
Click here to expand/collapse more articles by Christian HOLLE.
James Nickless
James has been a Partner with PwC since 2014, specialising in international tax and transfer pricing. He has advised on wide variety of cross border transactions, mergers and acquisitions, and tax controversy matters.  His unique skillset allows him to advise on cross border transactions holistically, combining international tax and transfer pricing skills.  James chairs PwC's thin capitalisation technical panel - Current at 20 January 2026
Click here to expand/collapse more articles by James Nickless.
Robert Pfeiffer
Robert works for PricewaterhouseCoopers. - Current at 18 May 2010

 

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