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The reconstruction provision in the new Australian transfer pricing rules paper

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Published on 18 Feb 15 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • effect of tax treaties on the operation of the reconstruction provision
  • the "form" and "substance” of commercial or financial relations between entities
  • what would independent parties dealing wholly independently have done?
  • how do reconstructed transactions affect the calculation of tax payable?
  • does section 815-140 rely on the operation of the reconstruction provisions in cases of excessive debt?

Author profile

Ian Fullerton CTA
Ian is a Barrister, Ground Floor Wentworth Chambers. - Current at 29 October 2019
Click here to expand/collapse more articles by Ian FULLERTON.

 

This was presented at 2015 Financial Services Taxation Conference .

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The reconstruction provision in the new Australian transfer pricing rules

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