Special Tax Topics 2026-27 - International tax - Thin capitalisation

This session provides an overview of key integrity rules governing debt and financing arrangements in the Australian tax system. It covers the classification of debt and equity interests, the operation of the reformed thin capitalisation regime from 1 July 2023, and the application of the fixed ratio, group ratio, and third-party debt tests. The session also introduces the debt deduction creation rules, focusing on their role in limiting inappropriate interest deductions and ensuring financing arrangements align with commercial and policy intent.

Upon successful completion of this topic, learners should have more of an awareness of:

• Explain the debt equity rules, distinguishing debt interests from equity interests.
• Explain the thin capitalisation regime & who is impacted.
• Explain the fixed ratio, group ratio and third-party debt tests under the thin capitalisation rules.
• Explain when the debt deduction creation rules apply.

This session forms part of the Special Tax Topics Series. These detailed sessions have been specifically designed for an online platform to ensure training is informative, immersive and engaging.

These sessions will:

• Ensure you get the critical knowledge you need while minimising your time out of the office.
• Assist you in providing proactive tax advice and identifying tax planning opportunities early.
• Help you avoid possible traps and pitfalls.
• Give you answers to the questions most relevant to you.

Our partnership with Thomson Reuters gives you the most up-to-date information, updated regularly and enhanced by our technical specialists.

Continuing Professional Development Hours

All sessions covered in our Special Tax Topics Series constitute verifiable CPD for CA ANZ and are likely to meet the Tax Practitioners Board's CPD requirements.

Related Packages

Looking for more? Our Essential Tax Updates perfectly complement these special topic sessions.