Australia: Legislation on interest limitation rules receives Royal Assent

New interest limitation (thin capitalization) rules

New interest limitation (thin capitalization) rules

Legislation containing new interest limitation (thin capitalization) rules received Royal Assent on 8 April 2024.

The Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Act 2023 passed both houses of Parliament on 27 March 2024 (read TaxNewsFlash), after a series of amendments were made in the Senate (relating to the forestry industry and a post-implementation review).

The Act:

  • Requires Australian public companies to disclose information about their subsidiaries in their annual financial reports by way of a “consolidated entity disclosure statement”
  • Amends the thin capitalization rules to limit the amount of debt deductions that multinational entities can claim in an income year



The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.