The transfer pricing benefit must be assessed and negated for each tax year, not on a hindsight basis over the total loan period. The determination of arm’s length profits, and any “excessive” interest deductions, had to occur year by year. This was fundamental to how the tran...
Employer SG contributions in2020/21were $74.1 billion. The amount of SG debt was $2.7 billion. The audit found that the ATO had not fully implemented its risk-based compliance strategy, which is designed to shift the focus from a reactive approach through enforcement to a preventative approach ...
The third amendment was signed on March 30, 2009, and fundamentally changed the nature of the LNIA to that of a fixed rate agreement for the remaining four years under the LNIA. The stated fixed interest rate was 6.835 percent but also included a 1 percent premium as well as an additiona...