The Australian Taxation Office (ATO) today released the following draft guidance:
- Draft income taxation ruling on the “third party debt conditions” an entity must meet to satisfy the new third party debt test in the thin capitalization provisions (TR 2024/D3) (read a December 2024 report prepared by the KPMG member firm in Australia)
- Draft practical compliance guideline update to Schedules 3 and 4 relating to the third party test under the thin capitalization provisions and restructuring in response to the thin capitalization provisions, respectively (PCG 2024/D3)
- Draft practical compliance guideline on the integrity measure relating to capital raised for the purpose of funding franked distributions (PCG 2024/D4)
The ATO also issued guidance on its website on the application of Division 15 to insurance premiums paid to nonresident insurers.