Treasury Laws Amendment (Making Multinationals Pay Their Fair Share - Integrity and Transparency) Act 2024 (23 of 2024)
Schedule 2 Thin capitalisation
Part 1 Amendments
Income Tax Assessment Act 1997
13 Section 820-10 (before table item 1)
Insert:
|
1A |
Subdivision 820-AA |
(a) how all or a part of the debt deductions claimed by an entity covered by the Subdivision may be disallowed under one of three tests (the fixed ratio test, the group ratio test or the third party debt test); and (b) how the entity can choose to apply which one of these tests applies; and (c) where the fixed ratio test applies, whether the entity can claim a special deduction in respect of amounts previously disallowed under the fixed ratio test. |