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Australia: Guidance on compliance approach to restructuring transactions in response to new thin capitalization rules

The draft guidance describes a series of low-risk and high-risk factors and a four-color-coded risk-assessment framework.

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October 15, 2024

The Australian Taxation Office (ATO) on October 9, 2024, issued draft guidance (Practical Compliance Guideline 2024/D3) setting out the ATO's compliance approach to reviewing restructuring transactions in response to the new thin capitalization rules introduced under the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity And Transparency) Act 2024.

The draft guidance describes a series of low-risk and high-risk factors and a four-color-coded risk-assessment framework (white, yellow, green, and red zones) denoting varying levels of scrutiny the ATO is likely to apply to restructuring transactions engaged in by taxpayers.

The draft guidance is open for comments until November 8, 2024.

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