Toby Knight, Anna Sartori and Gidon Waller have published a paper examining the application of transfer pricing, the debt deduction creation rules (DDCR), the new thin capitalisation rules and the general anti-avoidance rule (GAAR) to intragroup financing arrangements.
The paper was presented by Toby and Anna at the Tax Institute's National Transfer Pricing Conference held in Melbourne in October 2024. It summarises the relevant law and guidance of the above regimes, considers how each regime could apply to intragroup financing arrangements in particular, and considers possible interactions between each regime.
A copy of the paper can be accessed below.