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Draft ruling TR 97/D7 - Misapplication of Part IVA?

Publication date: 01 Aug 97 | Source: "THE TAX SPECIALIST" JOURNAL ARTICLE

Issue: Vol 1 No 1

Pages: pp. 2 - 3

Draft taxation ruling TR 97/D7, issued on 30 June 1997, deals with the taxation consequences for taxpayers of entering into certain linked or split loan facilities. In addressing the question of whether the additional interest incurred from those arrangements is deductible under sec. 51(1) of the Income Tax Assessment Act 1936, the Commissioner concludes in the draft ruling that the denial of deductions to such cases under sec. 51(1) "is at best problematic" [sic} and that Part IVA will be applied to such loan transactions. In fact, two interest components of the business loan fail to be considered under sec. 51(1) and must be considered separately.

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Christopher Bevan CTA
Chris is Barrister Wentworth Chambers. - Current at 01 July 2012
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