Australia: Guidance on debt deduction creation rules

The debt deduction creation rules will apply to assessments for income years starting on or after July 1, 2024.

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April 1, 2025

The Australian Taxation Office (ATO) released a guide on application of the debt deduction creation rules (DDCR), under which debt deductions relating to certain related-party financing arrangements may be disallowed.

The guide describes:

  • Who is and is not affected by the DDCR
  • How the DDCR interacts with other rules
  • The types of arrangements to which the DDCR applies
  • How the DDCR anti-avoidance rule applies to debt deductions
  • How to report on the DDCR using an international dealings schedule or reportable tax position

The DDCR will apply to assessments for income years starting on or after July 1, 2024.

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