Book a Meeting Book a Meeting

ATO Interest Deductibility for Investment Properties: Key Principles and Compliance Considerations

Interest on investment property loans is one of the most significant deductions available to Australian property investors. However, the ATO’s rules are highly specific, and compliance activity in this area has increased sharply in recent years.

Understanding how deductibility works — and where taxpayers commonly make mistakes — is essential to avoiding adjustments and an ATO scrutiny.

Core Rule: Deductibility Depends on the Use of Borrowed Funds

The foundational ATO principle is that interest is deductible only when borrowed funds are used for an income‑producing purpose, such as acquiring or maintaining a rental property.

This rule is consistently reflected in ATO guidance on investment‑related borrowing costs. If any portion of the funds is used privately, the interest must be apportioned so that only the income‑producing component is claimed — even when most of the loan relates to an investment property.

Common Misunderstanding: Loan Security is Irrelevant

Many taxpayers incorrectly assume that interest is deductible simply because the loan is secured by an investment property. This is not the case.

Under the ATO’s "tracing rule", deductibility is determined entirely by how the borrowed funds were used, not the security offered.

This rule applies equally to:

  • new borrowings
  • refinanced loans
  • redraws

Where redraws or refinanced funds are applied to non‑investment purposes, the loan becomes a mixed‑purpose loan, requiring interest to be apportioned. 

Refinancing and Redraws: How Contamination Occurs

Refinancing does not reset the tax character of a loan. The ATO requires taxpayers to trace each component of the refinanced loan back to its original use. If refinanced funds combine investment and non‑investment purposes, the mixed‑purpose nature continues, and interest apportionment must be maintained.

A single redraw for non‑investment use can permanently contaminate the loan. Once this occurs:

  • interest must be apportioned, and
  • repayments also need to be split between deductible and non‑deductible portions,
  • unless the private‑use component is moved into a separate loan facility.

Importantly, the contamination remains even if the private redraw is repaid immediately This is because each redraw is treated as a new borrowing with its own purpose.

ATO Compliance Activity: Data‑Matching Focus

Recent ATO compliance activity shows increased focus on redraw, refinance, and loan‑purpose behaviour. The ATO now data‑matches taxpayer claims with detailed residential loan information supplied by financial institutions, including:

  • redraw events
  • loan purpose coding
  • loan balances
  • refinancing activity

This allows the ATO to identify patterns of redraws, refinances, and loan‑purpose changes. Taxpayers who continue to claim full deductibility after private redraws are being specifically targeted.

The ATO has stated that redraw misuse is a significant source of lost revenue and remains a priority compliance area.

Case Example: Redraw Leading to Permanent Apportionment

A taxpayer originally borrowed $400,000 to purchase a rental property, making all interest deductible. Later, they redrew $30,000 from the same loan for non‑investment purposes. Through data‑matching, the ATO detected the redraw and noted that the taxpayer continued to claim 100% of the loan interest, triggering a compliance review.

Because the redraw created a mixed‑purpose loan, interest must be apportioned on a fair and reasonable basis. ATO guidance confirms that interest relating to the private‑use portion is non‑deductible, and repayments must also be split.

Example:

  • Original loan balance: $400,000
  • Redraw: $30,000
  • Private‑purpose component: 7.5%

Accordingly, 7.5% of all future interest becomes non‑deductible. 

Why Offset Accounts Attached to the Loan Can Help Avoid Contamination

Offset accounts provide a structural advantage because movement of funds in or out of an offset does not change the tax characteristics of the loan principal.

As a result:

  • no new borrowing occurs
  • no redraw event occurs
  • the loan purpose remains unchanged
  • no mixed‑purpose issue arises

Withdrawals from an offset are treated as accessing savings, not borrowed funds. This ensures the original loan’s deductibility remains intact.

Summary of Key Principles

  • Redraws are treated as new borrowings — private redraws permanently contaminate the loan.
  • Repaying a private redraw does not fix contamination.
  • Refinancing does not cleanse a mixed‑purpose loan — purpose is traced back to original use.
  • Offset accounts avoid contamination entirely by not altering loan principal.
  • ATO data‑matching means redraws, refinances and loan‑purpose changes are closely monitored.

Understanding these principles is essential to maintaining correct interest deductions and avoiding ATO adjustments.

For beginner investors or investors with significant portfolios, even small structural issues can create substantial tax leakage. If you would like a strategic review of your lending arrangements — or assistance designing a clean, optimised structure — our team can help.

Contact Exacte Advisors for tailored, high‑level guidance on managing interest deductibility across any size of property holding.



Article by


Danielle Baillie

Principal




Related Articles

Pay Day Super: Preparing Your Business for 2026
Blog

Pay Day Super: Preparing Your Business for 2026


Bucket Companies Explained: A Guide for Business Owners
Blog

Bucket Companies Explained: A Guide for Business Owners


Tax Planning For Australian SMEs: 5 Must Know Tips Before June 30
Blog

Tax Planning For Australian SMEs: 5 Must Know Tips Before June 30