House of Representatives
Treasury Laws Amendment (Making Multinationals Pay Their Fair Share - Integrity and Transparency) Bill 2023
Explanatory Memorandum
(Circulated by authority of the Assistant Minister for Competition, Charities and Treasury, the Hon Dr Andrew Leigh MP)Glossary
This Explanatory Memorandum uses the following abbreviations and acronyms.
| Abbreviation | Definition |
| ACA | Allocable cost amount |
| ADI | Authorised deposit-taking institution |
| ATO | Australian Taxation Office |
| BEPS | Base erosion and profit shifting |
| Bill | Treasury Laws Amendment (Making Multinationals Pay Their Fair Share—Integrity and Transparency) Bill 2023 |
| BCT | Business continuity test |
| CGT | Capital gains tax |
| Commissioner | Commissioner of Taxation |
| Corporations Act | Corporations Act 2001 |
| COT | Continuity of ownership test |
| EBITDA | Earnings before interest, taxes, depreciation, and amortisation |
| EU | European Union |
| GR | Group ratio |
| ITAA 1936 | Income Tax Assessment Act 1936 |
| ITAA 1997 | Income Tax Assessment Act 1997 |
| MNE | Multinational enterprise |
| OECD | Organisation for Economic Cooperation and Development |
| OECD's best practice guidance | OECD report on Limiting Base Erosion Involving Interest Deductions and Other Financial Payments Action 4 – 2016 Update |
| TAA 1953 | Taxation Administration Act 1953 |
| TC control interest | Thin capitalisation control interest |