The Commissioner made determinations under the transfer pricing rules in Division 13 of the Income Tax Assessment Act 1936 (ITAA36) and Subdivision 815-A of the Income Tax Assessment Act 1997 (ITAA97) that STAI had obtained a “transfer pricing benefit”. The determinations substituted...
are proposed to apply before and after the date of issue. Section 974-80 was intended to act as an integrity provision to ensure that for tax purposes, debt treatment is not extended to arrangements where a debt interest is issued to a connected entity, and the return paid to the connected...
“These actions form a critical part of our response to the revelations of unacceptable breaches of confidential information in parts of the firm’s tax practice,” the firmsaidin a media release. The string of confidentiality breaches in its tax practice began many years ago....