Treasury Laws Amendment (Making Multinationals Pay Their Fair Share - Integrity and Transparency) Act 2024 (23 of 2024)
Schedule 2 Thin capitalisation
Part 1 Amendments
Income Tax Assessment Act 1997
14 Section 820-10 (after table item 2)
Insert:
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2A |
Subdivision 820-EAA |
how all or a part of the debt deductions claimed by an entity covered by Subdivision 820-AA, 820-B or 820-C may be disallowed in relation to: (a) debt deductions in relation to the acquisition of CGT assets, or legal or equitable obligations, from associate pairs of the acquirer; or (b) debt deductions in relation to a financial arrangement that is entered into by an entity to fund etc. certain payments or distributions to one or more associate pairs of the entity. |
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2B |
Subdivision 820-EAB |
(a) concepts concerning third party debt; and (b) concepts that are relevant to entities that choose to apply the third party debt test. |