The Australian Taxation Office (ATO) is consulting on Draft Taxation Ruling (TR) 2024/D3 on the application of thin capitalisation third-party debt test and the related Schedule 3 of Draft Practical Compliance Guideline (PCG) 2024/D3 regarding the third-party debt test compliance approach. These form part of the ATO's suite of public advice and guidance products to assist impacted taxpayers following the enactment of the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Act 2024 (the Act) on 8 April 2024 (previous coverage). TR 2024/D3 sets out the Commissioner's view on certain interpretative issues in relation to the thin...