Submitted by
              Moderator - Board of Taxation Secretariat
          Date
              29/08/2016
          Issue
              Amend transfer pricing rules so that when a taxpayer’s gearing ratio falls within the safe harbour rations, the taxpayer’s debt deductions are priced, for the purposes of the transfer pricing rules, on the basis of the taxpayer’s actual gearing ratio and not by reference to a notional arm’s length capital structure.