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Determination on interaction between transfer pricing and debt/equity rules finalized

11 August 2008

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Approved Changes

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Australia

On 16 July 2008, the Australian Taxation Office released the final version of Draft Taxation Determination TD 2008/D3 on the interaction between transfer pricing and debt/equity provisions, discussed earlier this year. The Determination was not materially changed from the Draft and was issued as Taxation Determination 2008/20. Briefly, the Determination says that the classification of an arrangement under the debt/equity provisions will not be relevant in the determination of an arm's length consideration for the transfer pricing purposes.