Thin capitalisation
Published Date: 20 Jun 2024
The long journey of the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Bill 2023 (the Bill) through Parliament (first tabled on 22 June 2023), including two Senate Economics Legislation Committee reviews and a round of exposure draft consultation on amendments, has now ended with the Bill finally passing both houses of Parliament on 27 March 2024.
The thin capitalisation amendments will have a significant impact on multinational groups. The amendments will apply from 1 July 2023 (1 July 2024 for the debt deduction creation rules).
This session explores the current state of play, and will:
- Provide an overview of the new thin capitalisation rules
- Work through the detail of the fixed ratio test, group ratio test and the third party debt test
- Provide practical examples and considerations, including in the context of financial services, funds, non-bank lenders and outward/inward MNEs; and
- Consider any gaps and areas of uncertainty in the new laws together with any administrative guidance current at the time of the session.
Individual Session
Details
- Published By: Scott Heezen, Peter Scott
- Published On:20 Jun 2024
- Took place at:Amora Hotel Jamison Sydney & Online
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