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
5 Section 705-60 (after table item 6)
Insert:
|
6A |
Subtract from the result of step 6 the step 6A amount worked out under section 705-112, which is about *FRT disallowed amounts that the joining entity transferred to the *head company under section 820-590 |
To stop the joined group getting benefits both through higher *tax cost setting amounts for the joining entity's assets and through FRT disallowed amounts transferred to the head company |