Multinational groups, corporate taxpayers, and foreign investors—are you ready for the ATO’s sweeping new tax return requirements?
With Tax Time 2025 on the horizon, the Australian Taxation Office (ATO) has unveiled its updated income tax return forms, schedules, and instructions, introducing significant new disclosure requirements under the reformed thin capitalisation regime and newly introduced debt deduction creation rules (DDCR).
At Boa & Co. Chartered Accountants, we are already assisting clients—both Australian and international—in navigating these highly technical changes. If your business is subject to cross-border funding, corporate restructuring, or interest deductions, these new rules could affect you.
What’s New in 2025?
The new regime applies to general class investors for income years starting 1 July 2023 (thin cap) and 1 July 2024 (DDCR), depending on your balance date.
Whether your entity balances at 30 June, 31 December, or another date, your 2025 tax return will likely involve new reporting across multiple forms, including:
Short Form Local File
A new requirement for country-by-country (CBC) reporters to disclose ‘significant restructures’—which now includes any restructure prompted by thin capitalisation or DDCR changes. Required details include:
- Full description and value of the restructure
- Tax and commercial impact (Australian and global)
- Step plan and involved entities
Reportable Tax Position (RTP) Schedule
New Question 47 in Category C requires disclosure of:
- The restructure response to DDCR
- Risk self-assessment under PCG 2024/D3
- Links to Short Form or International Dealings Schedule (IDS)
International Dealings Schedule (IDS)
A brand-new Section H has been added, with up to six pages of disclosures for DDCR. Key reporting areas:
- Application of the DDCR and reasonings
- Payments or CGT asset transfers involving associate entities
- Details of any tax advice received on the restructure
Why This Matters
Even if your business is not yet directly affected, disclosure requirements may still apply, especially for early balancers and large multinationals with complex funding structures.
Failing to disclose, or disclosing inconsistently across multiple schedules, can trigger ATO scrutiny, penalties, or risk ratings under their compliance program.
This is not the year for guesswork or last-minute patchwork.
How Boa & Co. Can Help
Our tax specialists at Boa & Co. Chartered Accountants have already begun preparing clients for these expanded obligations. We provide:
- Custom disclosure mapping to ensure consistency across Short Form, IDS, and RTP schedules
- Risk assessments and restructure reviews in line with PCG 2024/D3
- Preparation of documentation and step plans for significant restructures
- Assistance for non-resident entities navigating these rules for the first time
Whether you’re a local corporate group, foreign-owned business, or CBC reporter, we’ll walk you through what needs to be disclosed—when, how, and why.
Act Now to Prepare for 2025 Reporting
With the ATO increasing transparency, now is the time to review your group structure, funding arrangements, and tax governance before lodgement deadlines arrive. Let our experienced advisors guide you through the maze of new reporting obligations.
📞 Contact Boa & Co. today at 1300 952 286
📧 Email us at [email protected]
🌐 Visit us at www.boanco.com.au
Let’s ensure you stay compliant—accurately, efficiently, and confidently.