Australia: Final determination released on deductibility of support payments to subsidiaries

Tax Controversy & Dispute Resolution ()
​The Australian Taxation Office (ATO) has released final Taxation Determination TD 2014/14 (final TD) outlining its views on whether certain payments described in the ruling as capital support payments made by an Australian parent company to its subsidiary are deductible. TD 2014/14 is relevant to any Australian company that makes intra-group payments to a subsidiary company located outside of Australia.