ATO finalises PCG on new thin capitalisation and debt creation rules - 22 August 2025

On 20 August 2025, the ATO released a final practical compliance guideline PCG 2025/2 titled Restructures and the thin capitalisation and debt deduction creation rules – ATO compliance approach.

The final PCG is largely the same as the draft. A number of additional examples have been added to the final PCG, discussed in the Tax Insight, but otherwise, there is no material shift on the stance of the ATO on these measures.