Finance and tax

Debt deductions and thin capitalisation review

Debt deductions not claimed elsewhere after applying thin-capitalisation, debt-deduction-creation and related integrity rules.

Who can claim

This deduction is available to individuals and companies.

  • The financing cost is a debt deduction connected with producing assessable income and is not claimed at another label.
  • The taxpayer has applied any relevant thin-capitalisation and debt-deduction-creation rules.

What you cannot claim

  • Do not claim private interest, principal repayments or an amount denied by a thin-capitalisation or integrity rule.
  • Do not duplicate rental, business or investment interest already claimed elsewhere.

How the amount is worked out

Start with the otherwise deductible financing cost, then apply use-of-funds apportionment, thin-capitalisation limits and debt-deduction-creation exclusions.

Records the ATO expects

  • Loan agreements
  • Use-of-funds tracing
  • Related-party records
  • Thin-capitalisation calculation

Where this rule comes from

Primary source: Income Tax Assessment Act 1997 Division 820 (Compilation 266 in force 1 July 2026). Reviewed 30 July 2026. Covers the 2025-26 and 2026-27 income years.

Next steps