Strategizing International Tax Best Practices – by Keith Brockman

ATO: arm’s length debt

The Australian Tax Office (ATO) has recently issued guidance on thin capitalization arm’s length debt and outbound interest-free loans.

The guidance is especially valuable as it provides a risk assessment framework outlining their compliance approach to arm’s length debt.

The ATO is known for its reference to risk assessment frameworks, as this trend will continue in other countries and is a valuable read.

https://www.ato.gov.au/law/view/document?DocID=COG%2FPCG20207%2FNAT%2FATO%2F00001

https://www.ato.gov.au/law/view/document?DocID=TXR%2FTR20204%2FNAT%2FATO%2F00001

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