Thin capitalization refers to a business situation where a significant portion of operations are financed through debt rather than equity capital, resulting in disproportionately high levels of interest expense deducted against taxable profits.
Key Aspects of Thin Capitalization:
- Interest deductions limited or denied if debt-to-equity ratios surpass thresholds like 3:1 or 1.5:1 based on jurisdiction
- Intended to prevent artificially inflating interest shields through related-party loans at favorable rates
- Exceptions may apply to financial institutions and when loans procured from arm’s-length third parties
Example:
Overzealous tax planning triggered Australia’s anti-thin capitalization rules after a family business financed an expansion mostly through low-interest shareholder loans.
Takeaways:
While debt financing yields tax benefits, authorities curb incentives for excessive leverage that could undermine taxbase integrity or pose financial stability risks. Proper structuring maintains compliance without impeding normal commercial activities.
