Private ruling: financing transaction
Published: March 2012
Ruling period: n 1 January 2011 to 31 December 2011 | n 1 January 2012 to 31 December 2012 | n 1 January 2013 to 31 December 2013
Date scheme commenced: 20 May 2011

Ruling: Q1: That for the purposes of section 230-15 of the Income Tax Assessment Act 1997 (ITAA 1997), any interest incurred by entity A in respect of the loan and any interest incurred in respect of its market funding should be regarded as either: (i) made in gaining or producing assessable income; or (ii) necessarily made in carrying on a business for the purpose of gaining or producing assessable income, by entity A. | A1: Yes. | Q2: That section 177F(1)(b) of the ITAA 1936 will not apply in respect of the identified schemes. | A2: Yes.

Relevant facts and circumstances: The taxpayer applied for a private ruling in relation to a financing transaction.

Relevant legislative provisions: Income Tax Assessment Act 1997 section 230-15 and | Income Tax Assessment Act 1936 section 177F.

Reasons for decision: Summary: Not applicable.

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