Australia’s Thin Capitalization Regime: Financial Entities and Authorized Deposit-Taking Institutions (ADIs) are Put on Notice

Until recently, Australia was largely silent on amendments to its thin capitalization regime. In April 2024, however, a major legislative reform was enacted, changing both the categories of entities the rules apply to and the tests that can be used to determine allowable debt deductions. In the same month, the Australian Taxation Office released a discussion paper on the attribution of risk-weighted assets to Australian branches of foreign banks. This article considers these initiatives and their significance for financial entities and ADIs.