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Australia: Consultation guide for Board of Taxation’s review of thin capitalization amendments

Consultation closes May 18, 2026.

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March 23, 2026

The Board of Taxation issued a consultation guide for its independent review of the operation of the amendments to Australia's thin capitalization rules.

The guide suggests issues for submissions, including in particular:

  • Practical examples of how entities have complied with the amended provisions
  • Details of how Australian entities have integrated the amended provisions and interactions within their group financing arrangements
  • Industry-specific issues resulting from the amendments
  • Types and number of stakeholders affected
  • Compliance time and costs in restructuring existing, or accessing new, financing facilities
  • Whether entities have reduced their level of debt financing in response to the amendments
  • Suggested solutions (both administrative and legislative)

The consultation closes May 18, 2026, with the Board expected to report back to the government by January 31, 2027.

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