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ATO Provides Guidance on Interaction of Thin Capitalisation Rules with Other Provisions

07 November 2024

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Approved Changes

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Australia

The Australian Taxation Office (ATO) has published guidance dated 3 November 2024 on how the thin capitalisation rules interact with other provisions. --- Interaction with other provisions How the thin capitalisation rules interact with other provisions. Interaction with other provisions The thin capitalisation rules limit the amount of debt deductions you can claim. Regard must also be given to other provisions in the income tax law, including the transfer pricing rules and the debt deduction creation rules (DDCR). Transfer pricing You must apply the transfer pricing rules before applying the thin capitalisation rules. Debt deductions remaining after the application of...