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Rethinking the interest deduction rules in light of the Chevron Australia case Karrie Sadiq

By: Sadiq, Kerrie.
Material type: ArticleArticlePublisher: 2018Subject(s): PRECIOS DE TRANSFERENCIA | INTERES | IMPUESTOS | DEDUCCIONES | AUSTRALIAOnline resources: Click here to access online In: Bulletin for International Taxation v. 72, n. 9, September 2018, p. 545-553Summary: Based on the case of Chevron Australia (2017), this article argues that excessive debt loading and the transfer mispricing of financial transactions could be addressed by a limited formulary apportionment rule for debt deductions. The article also offers insights into the likely implications of the global adoption of such a model.
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Resumen.

Based on the case of Chevron Australia (2017), this article argues that excessive debt loading and the transfer mispricing of financial transactions could be addressed by a limited formulary apportionment rule for debt deductions. The article also offers insights into the likely implications of the global adoption of such a model.

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