Finalised ATO guidance on restructures, thin capitalisation and debt deduction creation rules released

The PCG outlines the ATO’s compliance guidance on the application of the general anti-avoidance rule and the debt deduction creation rules.

The Australian Taxation Office (ATO), on 20 August 2025, released its (almost) finalised guidance on restructures and the thin capitalisation and debt deduction creation rules (DDCR), Practical Compliance Guideline PCG 2025/2 (the PCG). See related article:Third-party debt test and restructures in response to the thin capitalisation changes The PCG outlines the ATO’s compliance guidance on the application of the general anti-avoidance rule (Part IVA) and the DDCR specific anti-avoidance ...

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Authors: Julian Humphrey, Justin Orders,

Published Date: 20 August 2025