Pitcher Partners | New thin capitalisation rules

The Government will implement new thin capitalisation rules that will operate from 1 July 2023. The proposed new rules will apply to deny interest deductions for taxpayers with foreign shareholders, or foreign operations, or that are part of multinational groups. The new rules (as currently drafted) seek to change the basis of acceptable gearing for tax purposes from an asset-based test to an earnings-based test. In an environment of rising interest rates, the new earnings-based approach is likely to have a significant impact on taxpayers, as they will no longer be able to rely on a safe-harbour asset-based gearing ratio.
This webinar will:
Explain how the each of the three new earnings based tests will operate and their impact on the deductibility of interest costs
Explore options available under the new rules
Consider issues affecting trusts and managed funds
Outline potential deficiencies in the current draft rules that Treasury should be considering
Identify issues in respect of financing arrangements that need to be considered prior to 1 July 2023