We refer to the changes to the thin capitalisation regime as enacted by the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Act 2024 (Cth) and the recent draft taxation ruling TR 2024/D3 and updated draft practical compliance guidance PCG 2024/D3 released on 4 December 2024 in respect of those changes.
This letter requests that the Commissioner publicly extend the timeframe for elections made by taxpayers under sections 820-46 and 820-47 of the Income Tax Assessment Act 1997 (Cth) (ITAA 1997) in the first year of the new thin capitalisation regime, and the period to revoke elections (where relevant), for a reasonable period following finalisation of TR 2024/D3 and PCG 2024/D3.
