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04 Sep 09 Joint submission on TD 2009/D2 (non-share equity interest issued at or through a PE)

On 7 August 2009, a joint submission in respect of TD 2009/D2 (Income tax: when is a non-share equity interest "issued at or through a permanent establishment" for the purposes of s 215-10(1)(c) of ITAA 1997?) was lodged with the ATO on behalf of CPA Australia, National Institute of Accountants, the Taxation Institute of Australia, the Institute of Chartered Accountants in Australia and Taxpayers Australia.

The joint submission states: "The Draft Determination adopts an overly restrictive interpretation of the scope of s 215-10(1)(c) which subsequently results in the franking exclusion provided to Authorised Deposit-Taking Institutions (ADIs) under s 215-10 being more limited than that originally intended."

For a copy of the joint submission, go here.

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