David Bell, ATI

David Bell, ATI


David is a transfer pricing partner and cross-border financing specialist in Deloitte’s Melbourne office. He has over 20 years consulting experience in Australia, Singapore and the US. David specialises in the analysis of cross-border financing issues including loan pricing, the application of the arm’s length debt test, cash pooling arrangements, guarantee pricing and the determination of arm’s length break fees for hybrid financing instruments. He has significant experience in the application of the arm’s length debt test for thin capitalization purposes in the infrastructure, property, technology and resources sectors.

All Sessions by David Bell, ATI

9:30 am - 10:30 am

Session 27.2: Arm's-length debt amount

Corporate Stream

With the ATO’s increasing scrutiny on debt deductions and the interaction with the thin capitalisation provisions, this session will examine the arm’s length debt amount (ALDA), including:

  • What is the ALDA, and how is it used?
  • What are the practical issues and common pitfalls in applying the ALDA?
  • What is the ATO’s compliance approach to the arm’s length debt test outlined in PCG 2020/7?
  • What is the interaction with the transfer pricing regime? and
  • Practical advice on managing the ATO’s risk assessment framework.