We’ve published the final PCG 2025/2 Restructures and the new thin capitalisation and debt deduction creation rules – ATO compliance approach.
This guideline sets out our practical compliance approach to restructures carried out in response to the new thin capitalisation rules and debt deduction creation rules (DDCR). We've incorporated submissions from stakeholders into the finalised guideline. This includes additional permissive guidance on types of low-risk restructures that taxpayers can enter into in response to the new laws.
We have not included schedule 3 in the guideline, which was previously released for consultation in December 2024. We'll update the guideline with schedule 3 when we publish the final taxation ruling TR 2024/D3 Income tax: aspects of the third-party debt test in September.
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