Tax Forum: Limiting Debt Deductions - a look at the new thin capitalisation rules

By Jay Prasad, Ria Neilson

Managing Associate Jay Prasad and Senior Associate Ria Neilson published a paper on Australia's
new interest limitation – or thin capitalisation – tax rules, including the new debt deduction creation integrity rules (or DDCR).

The paper was presented at the Tax Institute's NSW Tax Forum held in Sydney in May 2024. The paper examines the global context for the changes and provides a brief history of Australia's interest limitation rules. It also summarises some of the key features of the new thin capitalisation rules and considers the related changes to Australia's transfer pricing regime, and the DDCR.

A copy of the paper can be accessed below.