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Thin capitalisation and debt financing - The state of play paper


In the May 2013 Federal Budget, the Government announced the most significant changes to the thin capitalisation rules since their commencement in 2001. It also announced certain related measures that intend to limit deductions for financing costs. This paper explores those announced changes and the potential implications. It covers:

  • the new “safe harbour” limits
  • implications of the repeal of section 25-90
  • proposed amendments to section 23AJ
  • issues associated with re-financing.

Author profiles

Simon Jenner CTA
Simon is a Partner in the Financial Services Tax practice at EY, specialising in banking and capital markets. Simon has over 24 years’ experience advising large corporates on a variety of tax issues, including capital management, capital raisings, mergers, acquisitions, disposals and the application of the tax consolidation regime. He has also advised extensively on the application of the taxation of financial arrangements rules. - Current at 11 February 2021
Click here to expand/collapse more articles by Simon JENNER.
Nishlin Moodley CTA
Nishlin is a Senior Tax Manager at Westpac. - Current at 30 May 2019
Click here to expand/collapse more articles by Nishlin MOODLEY.


This was presented at Corporate Tax Retreat .

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