New Zealand tightens stance in updated TP guidance, introduces thin capitalisation infrastructure exemption
New Zealand’s Inland Revenue (IR) has issued updated guidance on Transfer Pricing Documentation and Thin Capitalisation Rules on 31 March 2026, replacing earlier versions from 2025 and 2021. The transfer pricing (TP) documentation guidance
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Australia: ​​ATO consults on thin capitalisation compliance, risk-weighted asset allocation for foreign bank branches
The Australian Taxation Office has opened a public consultation on Draft Practical Compliance Guideline PCG 2026/D1, covering thin capitalisation and the allocation of risk-weighted assets to Australian branches of foreign banks. This
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Australia consults Board of Taxation’s review of thin capitalisation amendments
The Australian Board of Taxation released a consultation guide marking the beginning of a formal statutory review of recent reforms to the nation's thin capitalisation rules in March 2026. This consultation guide outlines an independent statutory
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Korea (Rep.) introduces transfer pricing reforms, Pillar Two rollout
Korea (Rep.) has published Presidential Decree No. 36128, partially amending the enforcement Decree of the International Tax Adjustment Act, in the Official Gazette on 27 February 2026. The Decree introduces sweeping updates to its international tax
See MoreAustralia 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
See MoreAustralia: 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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Colombia: DIAN mandates certification for third-party debts under thin capitalization rules
The Colombian tax authority (DIAN) issued Ruling 803 of 23 September 2024, released on 1 November 2024, which provides guidance on the necessary certification of third-party debts for interest deduction purposes under the thin capitalization
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Australia: ATO issues guidance on thin capitalisation rules, related provisions
The Australian Taxation Office (ATO) released guidance on 3 November 2024, outlining how the thin capitalisation rules interact with other provisions. The thin capitalisation rules limit the amount of debt deductions you can claim. Regard must
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France sets interest deductibility rate limit for shareholder payments
France’s Ministry of Finance released the quarterly TMP (taux moyen pratiqué) rate to determine the annual market rate limit for deducting interest paid to shareholders. French law allows corporations to deduct annual shareholder interest
See MoreAustralia endorses OECD subject to tax rule for multinational tax reform
Andrew Leigh, the Australian Assistant Minister for Competition, Charities, and Treasury, announced that Australia is committed to multinational tax reform through a Statement of Support for the OECD's 'Subject to Tax Rule' on 20 September
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Armenia lowers Central Bank refinancing interest rate
Armenia’s Central Bank has lowered the refinancing interest rate from 7.75% to 7.50%. This marks the sixth rate reduction in 2024, following a previous drop of 9.25%. The Central Bank's refinancing rate influences the deductible interest on
See MoreAustralia: Guidance on Thin Capitalisation Rules Published Online
Following the enactment of the new thin capitalisation laws in April 2024, the ATO has developed web guidance to assist taxpayers in applying the new rules, which are effective for income years commencing on or after 1 July 2023. Under the rules,
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France: Tax Authority updates interest deduction rates for shareholder loans
The French tax authority has updated the interest rates used to define the deductibility of interest payments made to shareholders. These updates are pertinent to companies with fiscal years ending between 31 December, 2023, and 29 June,
See MoreAustralia publishes guidelines to address amendments to thin capitalisation rules
The Australian Taxation Office (ATO) published on Friday, 10 May, 2024, a list of priority public advice and guidance topics regarding the modifications to the thin capitalisation rules. Additionally, the ATO mentioned that it will update the
See MoreAustralia proposes laws on interest limits, foreign investment fees, and taxation for general insurers
The Australian Parliament has recently approved the following bills, which are awaiting Royal Assent. The bills are as follows: The Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Bill of 2023
See MoreAustralia offers additional guidance on new thin capitalization rules
On 8 April 2024, the Australian Taxation Office (ATO) declared additional consultations about the guidance for the new thin capitalization rules by the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share-Integrity and Transparency)
See MoreArmenia: Central bank lowers refinancing interest rate
On 12 December 2023, the Armenian Central Bank announced that it lowered the refinancing interest rate from 9.5% to 9.25%. This is the fifth interest rate reduction for 2023. The previously reduced refinancing interest rates are as follows:
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