Addressing profit shifting through the artificial loading of debt

On 6 November 2013, the Treasurer and the then Assistant Treasurer announced in a joint media release that the government would proceed with amendments for the following package of measures. These measures are aimed at addressing aggressive tax structures that seek to shift profits by artificially debt loading into Australia. The measures were originally announced by the former government in the 2013–14 Budget.

  • Tightening and improving the thin capitalisation rules.
  • Changes to the exemption for foreign non-portfolio dividends (section 23AJ of the Income Tax Assessment Act).

The first of these measures applies to income years commencing on or after 1 July 2014, while the section 23AJ changes apply to distributions and non-share dividends made from 17 October 2014.

Legislation and supporting material

The legislation received royal assent on 16 October 2014:

Media release

Refer to the following:

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    Last modified: 17 Nov 2014QC 34705