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Australian Tax Office issues draft Practical Compliance Guidance on debt deduction creation rules and restructures

11 October 2024

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Tax Alerts, National/Federal Taxation, G...

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Australia

The new draft Practical Compliance Guideline (PCG) provides the Australian Tax Office's (ATO's) compliance approach to reviewing arrangements that have been restructured in response to the new debt deduction creation rules (DDCR).The ATO may apply a specific DDCR anti-avoidance rule or the general anti-avoidance rule to cancel all or part of a tax benefit.A color-coded risk-assessment framework in the PCG helps illustrate the ATO's level of compliance scrutiny, based on low and high-risk factors; general guidance and examples of how the rules operate are also provided.The ATO plans to issue additional guidance regarding the thin-capitalization rules. Executive summaryThe Australian Taxation Office...