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

5   Section 705-60 (after table item 6)

Insert:

6A

Subtract from the result of step 6 the step 6A amount worked out under section 705-112, which is about *FRT disallowed amounts that the joining entity transferred to the *head company under section 820-590

To stop the joined group getting benefits both through higher *tax cost setting amounts for the joining entity's assets and through FRT disallowed amounts transferred to the head company


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