We’ve published 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. We've prioritised this guidance based on the feedback we received during our public consultation earlier in 2024.
The draft guidance is open for public comment until 8 November 2024. Refer to the instructions section in PCG 2024/D3 to submit your comments.
We'll continue to update our web guidance on DDCR and the Thin capitalisation rules.
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