Become a Member
Membership
Education
Events
Resources
Tax Knowledge Exchange
About us
Contact us
  2026 Thin capitalisation

Keynote Address: Thin Capitalisation

Source: New South Wales

Published Date: 18 Jun 2026

 

Sorry, this is subscriber only content.

If you're not yet a subscriber, to gain access to this material and much more - Subscribe Now.

Already a Subscriber? Login now

Subscribe Now

Already a Subscriber? Login now

The third-party debt test was introduced as an alternative test for infrastructure and real property taxpayers under the new thin capitalisation regime. While intended to provide a simpler and more streamlined approach than the former arm’s length debt test, the rules have raised several complex interpretational challenges. This keynote explored key concepts emerging from the regime, including commercial operations, recourse and Australian assets. Speakers also examined the ATO’s evolving views and discuss the practical implications for infrastructure investors and advisers.

Individual Session

Author(s): Michael O'Meara
Materials from this session:

Author(s)

Details

The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))

("TTI")

The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.

Tags

2026 Thin capitalisation

Share this page