Exploring the practical implications of recent tax reforms
Australia's debt deduction creation rules (DDCR) raise complex technical and practical issues in the context of double tax agreements, cash-pooling arrangements, and conventional related party financing arrangements. In a paper presented at the Tax Institute's annual Financial Services Conference in Sydney in March 2026, Ellen Thomas and George Bishop explore the DDCR through practical examples and case studies, including a retrospective analysis of the Noza Holdings and Orica decisions in light of the introduction of the DDCR and a consideration of ATO guidance regarding restructurings in response to the DDCR.
The authors also consider whether the DDCR, part of Australia's thin capitalisation tax regime, achieves its purported aims.
We invite you to read the full paper.