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

14   Section 820-10 (after table item 2)

Insert:

2A

Subdivision 820-EAA

how all or a part of the debt deductions claimed by an entity covered by Subdivision 820-AA, 820-B or 820-C may be disallowed in relation to:

(a) debt deductions in relation to the acquisition of CGT assets, or legal or equitable obligations, from associate pairs of the acquirer; or

(b) debt deductions in relation to a financial arrangement that is entered into by an entity to fund etc. certain payments or distributions to one or more associate pairs of the entity.

2B

Subdivision 820-EAB

(a) concepts concerning third party debt; and

(b) concepts that are relevant to entities that choose to apply the third party debt test.


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