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.
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: