Finance
Human Resources
Technology
Australian business

Refinancing ATO Debt: When Interest Is Deductible

A decision tree diagram comparing a company borrowing to pay its tax debt against a director borrowing personally, with tick and cross outcomes.
Scale Suite manages finance and HR for growing Australian businesses. Drop the team a message here →

Since the general interest charge lost its tax deduction, the case for refinancing ATO debt has stopped being marginal. Non-deductible GIC near 11 per cent costs a base rate company the equivalent of 15.4 per cent before tax. Worked figures use the June 2026 quarter effective rate of about 11.6 per cent; at the July to September 2026 rate of 11.43 per cent the effective rate is about 12.1 per cent, which lifts each figure by roughly 4.5 per cent. Interest on a deductible business facility at the same headline rate costs the equivalent of 8.25 per cent after tax, close to half. But the whole arbitrage rests on one word, deductible, and deductibility depends entirely on who borrows and what the debt is. Get the structure right and the refinance pays for itself. Get it wrong, most commonly by a director borrowing personally to bail out the company, and you swap non-deductible interest for different non-deductible interest plus a security over the family home. This guide maps the decision tree.

Published: July 2026

The Arbitrage in One Set of Numbers

Start with why this is worth structuring carefully. Take $200,000 of tax debt. Check the current GIC rate before you model a live refinance.

Left with the ATO at an effective 11.6 per cent (June 2026 quarter basis; see rate note above), the annual interest is about $23,200, none of it deductible, requiring roughly $30,900 of pre-tax profit for a 25 per cent company to fund.

Refinanced into a deductible business facility at, say, 11.5 per cent, the annual interest is $23,000, but the deduction returns $5,750 at the company rate, for a true after-tax cost of $17,250, funded by $23,000 of pre-tax profit. Same headline rate, roughly $7,900 a year cheaper in pre-tax terms, before counting the second benefit: the ATO stops being your lender, which removes the enforcement risk, the credit-reporting exposure and the refund-offsetting that come bundled with tax debt.

Even a facility priced meaningfully above GIC can win. For a base rate company, the break-even is a deductible rate around 15.4 per cent; below that, borrowing beats owing the ATO. At the 30 per cent company rate the break-even sits near 16.5 per cent. At the top personal marginal rate including Medicare, the break-even approaches 22 per cent. The arithmetic is rarely the hard part. The deductibility is.

Worked comparison: $185,000 trade tax debt

A hypothetical $3 million revenue trade company with 16 staff carries $185,000 of activity statement and income tax debt. Three options:

  • Stay on a 24-month ATO plan. Rough total GIC over the plan life: $18,000 to $22,000, non-deductible, plus new BAS paid in full alongside. Enforcement pauses while conditions are met; refunds still offset.
  • Company facility at 12.5 per cent deductible. Annual interest about $23,100 before tax, after-tax cost about $17,300 at 25 per cent, and the ATO balance clears in week one. Establishment fees of $2,000 to $4,000 are still cheaper than a year of non-deductible GIC on many files.
  • Director home loan redraw, paid straight to the ATO. Interest may sit at 6.5 per cent on the mortgage, but if the director’s interest is not deductible, the after-tax personal cost can still beat GIC on rate alone while creating the worst security and structure outcome in the set. This path needs specific tax advice before any dollar moves.

For many viable businesses, option two is the practical win. Option one is right when borrowing is unavailable. Option three is the trap path when taken unstructured.

The Rule That Decides Everything

Interest is deductible where the borrowing has the required connection to producing assessable income or carrying on a business for that purpose. Applied to tax debts, the case law and ATO position resolve into a pattern that sounds like a technicality and behaves like a wall:

  • A company borrowing to pay its own tax debts can generally deduct the interest. A company’s income tax, GST and PAYG withholding liabilities arise from carrying on its business, and borrowing to meet them preserves the working capital the business runs on. The nexus holds, and the interest is deductible to the company.
  • An individual borrowing to pay their own income tax generally cannot. Income tax is a private liability of the person, even when the income taxed came from a business. A sole trader or partner who borrows to pay their personal income tax bill is funding a private outgoing, and the interest carries no deduction.
  • An individual in business borrowing to pay the business’s own obligations is different again. GST, PAYG withholding and employee super are obligations of carrying on the enterprise itself, and borrowing to fund them sits on the business side of the line for a sole trader in a way their personal income tax does not.

The pattern to internalise: follow the liability, not the money. Whose debt is it, and did it arise from carrying on a business? Those two questions do nearly all the work, and they are also why the same refinance can be efficient in one structure and worthless in another. This is general information only; confirm your arrangement with a registered tax agent before you commit.

The Director Trap

Here is the structure that fails, and it fails constantly because it is the path of least resistance when a bank says no to the company.

The company owes the ATO $180,000. The company’s borrowing capacity is exhausted, so the director borrows personally, often against the home, and pays the company’s debt directly. The outcome is the worst available combination: the director’s interest is generally not deductible, because the director has no relevant income-producing connection to paying someone else’s tax bill, and the family home now secures a struggling company’s historical liabilities. The company’s debt is gone; the household’s has just begun, at full after-tax cost.

If personal capacity is truly the only capacity available, structure matters enormously and the details belong with a tax adviser before a dollar moves: whether funds are advanced to the company as a documented loan on commercial terms, what the company then does, how repayments and any interest flow back, and what Division 7A and security implications follow. The unstructured version, director pays ATO from a personal redraw, is the one that delivers no deduction and maximum personal exposure, and it is the version people execute in a stressful week without advice. The two hours of advice cost less than one month of the interest difference.

Directors should also weigh director penalty exposure on any unpaid PAYG withholding or super guarantee inside the balance. Refinancing the company debt can remove the company interest meter, but personal director penalty rules run on their own statutory conditions.

The Structures That Work, In Order of Preference

  • The company refinances itself. A business facility in the company’s name, secured against business assets where possible, drawn to clear the ATO in full. Cleanest nexus, cleanest deduction, and it converts a regulator relationship back into an ordinary lender relationship. Lenders exist across the spectrum here, from mainstream banks for well-secured files to specialist business lenders who write tax-debt refinances explicitly; pricing varies with security and file quality, which is exactly why the grossed-up comparison should be run per quote rather than assumed. Typical SME facility pricing for tax-debt clearances often sits somewhere in the high single digits to mid-teens, depending on security and credit quality.
  • Asset-backed release. Where the balance sheet holds unencumbered equipment, vehicles or property, a facility against those assets typically prices better than unsecured working capital and keeps the borrowing squarely inside the business. Sale-and-leaseback on bona fide business assets sits in the same family, with its own trade-offs.
  • Working capital structures against the cycle. For businesses whose real problem is the cash conversion cycle rather than accumulated losses, a receivables-backed facility can clear the ATO and fund the cycle that created the debt in the first place. Clean B2B debtors from creditworthy customers are the usual collateral. The relevant point here is that the borrowing is unambiguously for business purposes when structured to fund trading liabilities.
  • The payment plan as the fallback, not the default. Where no facility is available on sensible terms, an ATO payment plan remains the tool, with clear eyes: interest keeps accruing non-deductibly for the plan’s life, every new obligation must be paid on time alongside it, and a remission request should travel with the proposal. A plan is the right answer for a viable business without borrowing capacity. It is the wrong answer chosen by default for a business that never ran the comparison.

One honesty check belongs above all the structures: refinancing converts a tax debt into a commercial debt, it does not repair the operating problem that created it. A business that accumulated $200,000 of ATO arrears has been under-provisioning for a long time, and a refinance without a provisioning fix, obligations transferred weekly to a tax reserve as revenue and payroll occur, is a two-year loop back to the same place, this time with the assets already pledged. Fixing that rhythm is standing work for an embedded finance team, and it is the difference between refinancing once and refinancing as a lifestyle.

What Lenders Will Ask For

Expect a clean, current set of numbers. At minimum: last six months of bank statements, aged receivables and payables, a recent BAS history, a simple cashflow forecast for the next 13 weeks, and a one-page explanation of how the debt arose and what changed. Businesses whose books are months behind pay more for money or get declined. The cash flow forecast calculator and when will I run out of money tools are useful pre-work; so is bringing bookkeeping current before the credit application, not during it.

If the ATO has already issued an intent letter or recovery correspondence, disclose it early. Surprises on credit files kill more tax-debt refinances than interest rates do.

The Decision Tree, Stated Plainly

Whose debt is it? If the company’s: can the company borrow on any sensible terms? If yes, refinance in the company, deduct the interest, and fix the provisioning rhythm. If no, run the payment plan properly and ask why the company is unbankable, because that answer matters more than the debt. If the debt is a sole trader’s or partner’s: split it. The business obligations, GST, withholding, super, sit on the deductible side of a refinance; the personal income tax component does not, and no restructuring enthusiasm changes that. And if the plan involves a director’s personal borrowing for a company’s debt: stop, get specific advice on structure first, and treat the family home as the last asset committed, not the first.

Expensive option versus practical option

Expensive option: leave $200,000 with the ATO for two years on a flat plan, pay roughly $20,000-plus of non-deductible GIC, absorb refund offsets, and carry credit-reporting risk if the balance stays above the disclosure thresholds without engagement.

Practical option: clear the balance with a company facility under 15 per cent deductible, pay $12,000 to $18,000 after-tax interest in year one on a reducing balance, and redirect the old GIC cash into a tax reserve so the debt cannot reform. Pair the refinance with weekly bookkeeping and BAS provisioning; the finance cost of doing that properly is usually a fraction of the interest saved. For broader cash discipline, see the 90-day cash survival plan and working capital for SMEs.

Related resources and next reading

FAQ

Is interest on a loan to pay off ATO debt tax deductible?
It depends on who borrows and whose debt it is. A company borrowing to pay its own tax debts can generally deduct the interest because the liabilities arise from its business. An individual borrowing to pay personal income tax cannot, and a director borrowing personally to pay the company’s tax generally gets no deduction either.

Why refinance at all instead of keeping an ATO payment plan?
Because GIC is no longer deductible while genuine business borrowing usually is, so even a similar headline rate is far cheaper after tax, and refinancing removes the enforcement, credit-reporting and refund-offset consequences that travel with tax debt. Plans remain right for viable businesses without borrowing capacity.

What rate makes refinancing worthwhile?
For a base rate company, any deductible facility below roughly 15.4 per cent beats GIC near 11 per cent effective, because the grossed-up cost of non-deductible interest is the effective rate divided by one minus your tax rate. Run the comparison per quote; the break-even moves with your tax rate and the current GIC rate.

Can a sole trader deduct interest on a loan to pay their tax bill?
Not for their income tax, which is a private liability even when the income came from the business. Borrowing to fund the business’s own obligations such as GST and PAYG withholding sits differently. Mixed debts should be split and structured with advice.

Is it a good idea for a director to borrow against the house to pay company tax?
Unstructured, it is usually the worst available option: no deduction for the director and the family home securing a company’s historical debt. If personal capacity is truly the only capacity, the structure of how funds enter the company determines everything, and that is a specific-advice question before any money moves.

Will the ATO accept a partial refinance plus a payment plan for the rest?
The ATO assesses engagement and capacity, and a substantial upfront reduction funded by a facility typically strengthens a plan proposal for the remainder considerably. Pair it with a remission request where grounds exist.

Does refinancing the debt fix the problem?
It fixes the price of the debt. The debt existed because obligations were not provisioned as they accrued, and unless that rhythm changes, weekly transfers of GST, withholding and super to a reserve as they arise, the balance rebuilds. Refinance once, and fix the machine in the same month.

What documents do lenders want for a tax-debt refinance?
Usually bank statements, aged debtors and creditors, recent BAS history, a short cashflow forecast, and a clear explanation of cause and cure. Current books improve both approval odds and pricing.

Is this advice on what my business should do?
No. Deductibility outcomes turn on your entity type, the nature of each debt and how any refinance is structured, and this guide is general information only. Confirm your specific arrangement with a registered tax agent or adviser before committing.

About Scale Suite

Scale Suite is a Sydney-based provider of outsourced finance teams and fractional CFO services for Australian SMEs. We deliver weekly bookkeeping, payroll, BAS/IAS lodgement, cashflow reporting, management accounts, and strategic fractional CFO oversight, all as a fully embedded team that works inside your business.

CA-qualified, Xero Certified, and registered BAS Agents, we replace fragmented bookkeepers and once-a-year accountants with one responsive finance function at a fraction of the cost of full-time hires. We serve growing businesses across Sydney, Melbourne, Brisbane, and Perth, with packages starting from $1,500 per month and no lock-in contracts.

Visit Scale Suite | Browse our finance services | Pricing for finance packages | Explore finance tasks

Disclaimer

We review and check this guide periodically. At the time of writing (July 2026), all information was current. Scale Suite is a registered BAS Agent, not a licensed tax advisor or financial advisor. This content is general information only and does not constitute professional tax, financial, or legal advice. Some details may change over time.

Sources

  • Income Tax Assessment Act 1997, general deduction provisions (https://www.legislation.gov.au)
  • Australian Taxation Office guidance on deductibility of interest, including borrowings to fund tax liabilities of business entities (https://www.ato.gov.au)
  • Amending legislation denying deductions for ATO interest charges from 1 July 2025 (https://www.legislation.gov.au)
  • Australian Taxation Office, general interest charge rate publications (https://www.ato.gov.au/tax-rates-and-codes/general-interest-charge-rates)
  • Australian Taxation Office guidance on payment plans (https://www.ato.gov.au/businesses-and-organisations/having-trouble-paying/payment-plans) and business tax debt disclosure (https://www.ato.gov.au/businesses-and-organisations/having-trouble-paying/disclosure-of-business-tax-debts)

About Scale Suite

Scale Suite is a Sydney-based provider of outsourced finance and HR services for Australian SMEs. We deliver bookkeeping, financial reporting, payroll processing, fractional CFO support, recruitment, employee onboarding, people and culture support, and fractional HR oversight, all as a fully embedded team that works inside your business.

Employment Hero Gold Partner, CA-qualified, and Xero Certified, we replace fragmented finance and HR processes with one responsive, senior-level function at a fraction of the cost of full-time hires. We serve growing businesses across Sydney, Melbourne, Brisbane, and Perth, with packages starting from $1,500 per month and no lock-in contracts.

Contact us

Book Your Free Assessment

30 minutes with our team.

We'll review your current finance setup, compare the full cost of an internal hire against our embedded team, and show you exactly what your finance function should cost at your stage of growth.

You'll leave with a clear view of what's working, what's missing, and where you'd save.

No lock-in contracts. 30-day money-back guarantee.

Prefer to book directly?
Grab a time here.

Thanks, you're in. Grab a time below.
Pick a 30-min slot that works and we'll see you there.

Prefer us to call you? We'll reach out with the details you've provided.
Oops! Something went wrong while submitting the form.
"A collage of five people in circular frames: a woman smiling by a blue door, a young man in an apron, a man in a shirt near shelves, a woman with long hair in an office, and a man in profile view."

Book your free 30-minute strategy call now

Schedule My Call