Private ruling: Debt Note
Date of advice: 30 July 2019
Published: September 2019

Ruling: Q1: Will each of the coupons payable under the Note at the higher interest rate be wholly deductible to Entity X under subsection 230-15(2) of the Income Tax Assessment Act 1997 ? | A1: No | Q2: If the answer to Question 1 is No, will only a portion of the coupons payable under the Note at the higher interest rate be deductible to Entity X under subsection 230-15(2) of the Income Tax Assessment Act 1997 , with any balance not being deductible? | A2: Yes | Q3: Will each coupon payable under the Note at the lower interest rate be wholly deductible to Entity X under subsection 230-15(2) of the Income Tax Assessment Act 1997 ? | A3: Yes | Q4: Will each coupon payable under the Note be deductible to Entity X under subsection 230-15(2) of the Income Tax Assessment Act 1997 in accordance with subsection 230-15(5) of the Income Tax Assessment Act 1997 ? | A4: No

Relevant facts and circumstances: The taxpayer (Entity X) applied for a private ruling on the tax consequences, pursuant to Division 230 of the Income Tax Assessment Act 1997 , arising from issuing a Note.

Relevant legislative provisions: Income Tax Assessment Act 1997 Division 230 | Income Tax Assessment Act 1997 subsection 230-15(2) | Income Tax Assessment Act 1997 subsection 230-15(4) | Income Tax Assessment Act 1997 subsection 230-15(5)