Final Rules in Australia, Relief in India: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and once again we’re in Australia, where the tax authorities have finalized long-awaited rules limiting deductions companies can take on their debt Down Under.

They’re here! Australia finalized (most of) its long-awaited thin-capitalization and debt deduction creation rules this week, limiting the deductions multinational companies can claim on the interest on their debt.

For transfer pricing, the rules—particularly the debt reduction creation rules—contain a number of tests and restrictions on the deductions available for related-party debt. The DDCR applies to assessments for income years that began on or after ...