On 16 July 2008, the Australian Taxation Office released the final version of Draft Taxation Determination TD 2008/D3 on the interaction between transfer pricing and debt/equity provisions, discussed earlier this year.
The Determination was not materially changed from the Draft and was issued as Taxation Determination 2008/20. Briefly, the Determination says that the classification of an arrangement under the debt/equity provisions will not be relevant in the determinati…