ATO Finalizes Taxation Ruling on Third-Party Debt Test and Schedule 3 of Related Practical Compliance Guideline

The Australian Taxation Office (ATO) has published Taxation Ruling (TR) 2025/2, Income tax: aspects of the third party debt test in Subdivision 820-EAB of the Income Tax Assessment Act 1997. The Ruling sets out the ATO's views on aspects of the third party debt test (TPDT) in Subdivision 820-EAB of the Income Tax Assessment Act 1997. The focus of the Ruling is the third party debt conditions in section 820-427A. These conditions are relevant to working out an entity's third party earnings li…