Private ruling: Issue of product
Date of advice: 26 April 2016
Published: June 2016

Ruling: Q1: Is there a financial arrangement pursuant to section 230-45 of the ITAA 1997? | A1: Yes | Q2: Will the arrangement be treated as a financial arrangement under subsection 230-50(1) of the ITAA 1997? | A2: No | Q3: Will the losses from the arrangement be deductible pursuant to subsection 230-15(2) of the ITAA 1997? | A3: Yes | Q4: Will the accruals method provided for under subsection 230-100(2) of the ITAA 1997 apply to the gain or losses arising from the financial arrangement? | A4: Yes

Relevant facts and circumstances: The Taxpayer is seeking to raise funds from the market.


Reasons for decision: Summary: Is there a financial arrangement pursuant to section 230-45 of the ITAA 1997? All of the requisite requirements of the relevant legislation have been satisfied. Will the arrangement be treated as a financial arrangement under subsection 230-50(1) of the ITAA 1997? All of the requisite requirements of the relevant legislation have not been satisfied. Will the losses from the arrangement be deductible pursuant to subsection 230-15(2) of the ITAA 1997? All of the requisite requirements of the relevant legislation have been satisfied. Will the accruals method provided for under subsection 230-100(2) of the ITAA 1997 apply to the gain or losses arising from the financial arrangement? All of the requisite requirements of the relevant legislation have been satisfied.