This paper considers the application of the proposed thin capitalisation rules to Australian entities that are foreign controlled and foreign entities that operate in Australia. The paper focuses on the provisions contained in Subdivision 820-C which applies to inward investing entities that are not approved deposit-taking institutions (ADIs). Part 2 of this paper outlines the rules as they apply to inward investing entities. Part 3 highlights various issues for inward investing entities some of which are currently being addressed by the Government.
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