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Alternative assets insights: The ALDT and cross-border related-party interest-free loans

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Published on 01 Oct 20 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

This article discusses the latest ATO published guidance on the arm’s length debt test and cross-border related-party interest-free loans.

Author profiles

Edwin Baghdasarayan ATI
Edwin is a Transfer Pricing Partner within the PwC Australia Global Tax practice, based in Sydney. He has also spent time with the US firm in New York as well as the New Zealand firm in Auckland. He has practiced transfer pricing at PwC since 2007 and has been involved in assisting numerous Australian and foreign listed multinationals in their global transfer pricing across the entire lifecycle including consulting, structuring and planning, documentation, managing risk reviews, audits and APAs. His experience ranges across a variety of industries, including financial services, consumer & industrial products, resources, logistics/transport and the technology sector. - Current at 23 May 2022
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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
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