Australia: Draft determination released on non-deductibility of support payments

Tax Controversy & Dispute Resolution ()

The Australian Taxation Office (ATO) has released a draft Taxation Determination TD 20013/D3 outlining its views on whether support payments made by an Australian parent company to its subsidiary are deductible. The ATO position expressed in the draft tax determination (the draft TD) is that support payments are capital in nature and therefore not deductible.