Private ruling: Business expenses
Date of advice: 27 February 2020
Published: April 2020
Ruling period: Year ending 30 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Are you entitled to a deduction for interest incurred on money borrowed to pay income tax and Pay As You Go instalment amounts that arise from you carrying on a business as a sole trader? | A1: Yes. Based on the information provided, it is considered that you are entitled to a deduction under section 8-1 of the Income Tax Assessment Act 1997 for interest incurred on moneys borrowed to meet your tax obligations arising in relation to your business. Further information on business deductions can be found by searching 'QC 33867' on ato.gov.au.

Relevant facts and circumstances: You are a medical professional that carries on a business as a sole trader. You have rental property and share investments in your name which are negatively geared. You do not earn any employment income. You plan to borrow money to pay your Pay As You Go instalment amounts and year-end tax liabilities incurred in relation to your business activities. The borrowings will incur interest. For the purpose of this ruling, you will borrow the funds as planned and will use them for to pay taxation liabilities arising in relation to your business activities.

Relevant legislative provisions: Section 8-1 of the Income Tax Assessment Act 1997 | Section 25-5 of the Income Tax Assessment Act 1997