While the thin capitalisation rules have traditionally had limited application to many private groups, the new debt deduction creation rules (DDCR) that apply from 1 July 2024 are a clear creep into that space.
This is the first article in a series that aims to demystify the application of the tax consolidation rules in Part 3-90 of the Income Tax Assessment Act 1997 for private groups and small and medium enterprises (SMEs).