Multinational Tax Integrity: Thin Capitalisation Reform

On the 16th of March 2023, Treasury released the Exposure Draft for the Government’s Treasury Laws Amendment (Measures for Future Bills) Bill 2023 for public consultation. The Bill forms part of the Government’s legislative response to its Multinational Tax Integrity election commitment, and its place in the Government’s first-term legislative agenda was foreshadowed in the October 2022 Budget.

The Council was pleased to provide a submission to this consultation, focusing on the Government’s proposed thin capitalisation reforms. Our submission highlights some of the unintended consequences arising from the Bill’s drafting, and advocates for a more commercially practicable approach to the introduction of the tax reforms.

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