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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 Nickless has been a Partner with PwC since 2014, specialising in international tax and transfer pricing. He has advised on a 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 03 July 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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