ATO Finalises Guidance on Thin Capitalisation Restructures – What Businesses Need to Know
The Australian Taxation Office (ATO) has finalised Practical Compliance Guideline PCG 2025/2, which sets out how restructures will be assessed under Australia’s new thin capitalisation regime and the debt deduction creation rules (DDCR). For businesses with related-party financing or refinancing arrangements, this guidance is crucial. It introduces a four-zone “traffic light” risk framework, practical examples, […]