Private ruling: Infrastructure Securitisation Transaction - TOFA and Thin Capitalisation
Date of advice: 13 April 2016
Published: June 2016

Ruling: Q1: Will the accruals method under section 230-100 of the ITAA 1997 apply to the financial arrangements between SecureCo and the Government? | A1: Yes. | Q2: Will the allocation of gains arising from the financial arrangement between SecureCo and the Government using the compounding accruals method satisfy the requirements of paragraph 230-135(2)(a) of the ITAA 1997? | A2: Yes. | Q3: Will SecureCo be entitled to an exemption under section 820-39 of the ITAA 1997 from any debt deduction being disallowed under Division 820 of the ITAA 1997? | A3: Yes.