The Australian Taxation Office has published Practical Compliance Guideline PCG 2018/1, which provides guidance on the attribution of equity capital to overseas permanent establishments (PEs) for the determination of adjusted average equity capital (AAEC) of authorized deposit-taking institutions (ADIs) under the thin capitalization rules. The guideline is broken up into two main parts: Part A, which covers the attribution of ADI equity capital to an overseas PE; and Part B, which covers the…