The Australian Taxation Office (ATO) launched a public consultation on Practical Compliance Guideline (PCG) 2024/D3 – Restructures and the new thin capitalisation and debt deduction creation rules on 9 October 2024.
The ATO has published the Draft Practical Compliance Guideline PCG 2024/D3 Restructures and the new thin capitalisation and debt deduction creation rules. This follows the enactment of the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Act 2024 on 8 April 2024, which introduced new debt deduction creation rules (DDCR).
The draft guideline sets out the Commissioner’s practical compliance approach to restructures carried out in response to the DDCR. It provides a risk assessment framework for impacted taxpayers. The ATO has prioritised this guidance based on the feedback we received during its public consultation earlier in 2024.
The draft guidance is open for public comment until 8 November 2024.
Interested stakeholders are asked to refer to the instructions section in PCG 2024/D3 to submit comments.
