IDS 2024 – restructuring
An entity is required to complete an international dealings schedule (IDS) 2024 if it has written an amount or 'Y' (for 'yes') at any relevant labels (or trigger points and questions) in its tax return. For more information, see Who must complete an IDS.
Question 39a of the IDS 2024 requires an entity to provide information if it undertakes or implements a restructure or replacement of an arrangement during the 2024 income year in anticipation of the debt deduction creation rules (DDCR).
This covers information about the restructure or replacement of an arrangement that would have satisfied the conditions for Type 1: Acquisition case or Type 2: Payment or distribution case if the arrangement had not been restructured or replaced and had still been in place after 1 July 2024.
For more information, see Section D: Thin capitalisation.
IDS 2025
As the DDCR will apply from income years starting on or after 1 July 2024, specific questions in relation to the DDCR are included in the IDS 2025. This includes information in relation to any restructure or replacement of an arrangement that would have satisfied the conditions for Type 1: Acquisition case or Type 2: Payment or distribution case if the arrangement had not been restructured or replaced and had still been in place until after the DDCR was applicable.
PCG 2024/D3
We published Draft Practical Compliance Guideline PCG 2024/D3 Restructures and the new thin capitalisation and debt deduction creation rules on 9 October 2024. 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 the DDCR.
The draft guideline includes the Commissioner’s practical compliance approach to restructures carried out in response to the DDCR. It provides a risk assessment framework for affected taxpayers.
We will update this page once Draft PCG 2024/D3 has been finalised.
Reportable tax position (RTP)
Refer to the RTP Schedule and Instructions for information on Question 47.
This question requires disclosure of a taxpayer's risk assessment of restructures undertaken in response to the DDCR consistently with PCG 2024/D3.
For additional information, see RTP schedule 2025 instructions.