Private ruling: Thin capitalisation exemption
Date of advice: 3 December 2025
Published: 27 January 2026

Ruling: The Commissioner issued a Private Binding Ruling in relation to the application of the exemption from the thin capitalisation rules in Division 820 of the Income Tax Assessment Act 1997 (ITAA 1997) for special purposes entities pursuant to section 820-39 of the ITAA 1997.