Australia to consult thin capitalisation reforms
Australia’s government has asked the Board of Taxation to independently review the recent changes to Australia’s thin capitalisation rules. These changes were introduced in Schedule 2 of the Treasury Laws Amendment (Making Multinationals Pay
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Brazil: RFB updates rules on credit losses, interest on equity
Brazil’s tax authority, the Federal Revenue Service (RFB) announced that it updated Normative Instruction RFB No. 1,700/2017 on 4 December 2025 to clarify the tax treatment of credit losses and interest on equity (JCP). The changes respond to
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Ireland: Irish Revenue revises guidance on tax treatment of debt issuance costs, covering interest cap fees
Irish Revenue has issued eBrief No. 217/25 on 25 November 2025, updating the Tax and Duty Manual (TDM) Part 04-06-21 on the tax treatment of debt issuance costs, including interest cap fees. The update incorporates guidance on interest cap fees,
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Bolivia: Chamber of Deputies considers 2026 state budget proposal
Bolivia’s Executive Branch has submitted the 2026 General Budget Bill to the Chamber of Deputies on 31 October 2025, outlining a series of targeted tax incentives to reduce the cost of public debt operations conducted in foreign capital
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Australia: ATO issues guidance for private groups seeking to claim debt deductions
The Australian Taxation Office has released guidance on 14 November 2025, offering practical tips for private groups seeking to claim debt deductions. When preparing a tax return, private groups must make sure they check if the thin
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Australia: ATO issues final ruling on thin capitalisation third-party debt rules
The TPDT, introduced by the 2024 Treasury Laws Amendment, replaces the arm's length debt test for general investors and financial entities with a simpler, more streamlined method. The Australian Taxation Office (ATO) has issued Taxation Ruling TR
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Australia: ATO releases official form to revoke thin capitalisation test elections
The form enables eligible entities to revoke a previously made thin capitalisation test choice, including the group ratio or third-party debt tests. The Australian Taxation Office (ATO) released the official form for revoking thin capitalisation
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Philippines introduces tax reforms targeting large-scale metallic mining activities
Republic Act No. 12253 takes effect on 20 September 2025, affecting large-scale metallic mining contractors 150 days later, with implementing rules to be issued within 90 days. The Philippines has published Republic Act No. 12253, an Act
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Chile: SII clarifies thin capitalisation exemption for financial entities
The tax administration clarified that to be exempt from thin capitalisation rules, an entity must engage solely in financial activities (with limited complementary activities), certain assets are excluded from the 90% threshold, and the commercial
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Australia: ATO issues final compliance guideline on restructures and updated thin capitalisation rules
This guideline outlines ATO’s practical compliance approach for restructures undertaken in response to the new thin capitalisation and debt deduction creation rules (DDCR). The Australian Taxation Office (ATO) has published the final
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Tanzania enacts 2025-26 budget measures, includes new transfer pricing penalty
The measures will apply from 1 July 2025, unless otherwise specified. Tanzania's Finance Act 2025 was enacted on 30 June 2025, implementing tax measures from the 2025-26 Budget Speech with some adjustments to the initially announced
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Australia: ATO consults thin capitalization compliance guide
The ATO is seeking public feedback on a draft guidance to limit interest payment deductions on multinational debt. Comments are due by 30 June 2025. The Australian Taxation Office (ATO) has opened a public consultation regarding a draft guidance
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New Zealand consults thin capitalisation reforms to attract infrastructure investment
New Zealand’s Inland Revenue invites feedback on proposed changes to thin capitalisation rules to encourage foreign investment in private infrastructure projects. Submissions are open until 19 June 2025. New Zealand’s Inland Revenue has
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Belgium: Government presents tax reform plan to parliament, includes VAT measures
The Belgian Chamber of Representatives has released a policy note on 24 April 2025 detailing its tax reform plans for the upcoming year. The key measures of the tax reform plan include: Dividends received deduction rules Enhancing the
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Argentina sets rules for using reconstruction bonds to pay taxes and customs debts
Argentina’s tax authority (ARCA) has announced the regulations for companies and individuals to use Bonds for the Reconstruction of a Free Argentina (BOPREAL) to settle tax and customs debts through General Resolution 5675/2025 on 16 April
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Australia updates form, instructions for thin capitalisation test choice
The Australian Taxation Office (ATO) has updated its form and instructions for taxpayers on 13 February 2025, allowing individuals to select either the group ratio test or the third-party debt test (thin capitalisation test choice) for a specific
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Australia: ATO targets thin capitalisation in trust reviews
The Australian Taxation Office (ATO) has announced on 30 January 2025 regarding its focus on the updated thin capitalisation rules as part of its justified trust reviews. Thin capitalisation in focus for justified trust reviews How we're
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Australia: ATO consults implementation of thin capitalisation third-party debt test
The Australian Taxation Office (ATO) has initiated a public consultation regarding the implementation of the thin capitalisation third-party debt test . Additionally, it addresses the associated Schedule 3 of Draft Practical Compliance Guideline
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