This Subdivision sets out the thin capitalisation rules that apply to an Australian entity that has certain types of overseas investments and is not an authorised deposit - taking institution (an ADI ). These rules deal with the following matters:
• how to work out the entity's maximum allowable debt for an income year;
• how all or a part of the debt deductions claimed by the entity may be disallowed if the maximum allowable debt is exceeded;
• how to apply these rules to a period that is less than an income year.
820 - 85 Thin capitalisation rule for outward investing entities (non - ADI)
820 - 90 Maximum allowable debt
820 - 95 Safe harbour debt amount--outward investor (general)
820 - 100 Safe harbour debt amount--outward investor (financial)
820 - 105 Arm's length debt amount
820 - 110 Worldwide gearing debt amount--outward investor that is not also an inward investment vehicle
820 - 111 Worldwide gearing debt amount--outward investor that is also an inward investment vehicle
820 - 115 Amount of debt deduction disallowed
820 - 120 Application to part year periods