Private ruling: Thin capitalisation - financial entity
Date of advice: 10 February 2026
Published: 28 April 2026

Ruling: Q1: Are any of Company A, Company E, Company F and Company Y, each a member of the Company X tax consolidated group (Company X TCG), a financial entity as defined under paragraph (c) of the definition of 'financial entity' in subsection 995-1(1) of the Income Tax Assessment Act 1997 ( ITAA 1997 )? | A1: No. | Q2: Is Company X an outward investing financial entity (non-ADI) under subsection 820-583(3) of the ITAA 1997? | A2: No.