Private ruling: Issue of convertible redeemable preference shares (RPS)
Published: May 2014

Ruling: Q1: This ruling concerned whether the RPS issued is a debt interests as defined by Division 974 of the Income Tax Assessment Act 1997 (ITAA 1997). | A1: The Commissioner has ruled on the specific question. | Q2: This ruling concerned whether the Dividends (including the Unpaid Dividends included in the Redemption Price) deductible under section 230-15 of the ITAA 1997. | A2: The Commissioner has ruled on the specific question. | Q3: This ruling concerned whether the Commissioner will make a determination under section 177F of the Income Tax Assessment Act 1936 (ITAA 1936) that a whole or a part of the deduction for the RPS loss shall not be allowable in relation to the relevant income year. | A3: The Commissioner has ruled on the specific question.




Subject: Issue of convertible redeemable preference shares (RPS): In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided: