Published on 22 Aug 05
by THE TAX INSTITUTE
A joint professional body submission regarding TD 2005/D20 Income Tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997, if the issuer of an interest bearing instrument can change the rate of interest that will become payable to any rate (including zero) that it chooses at its sole discretion, does the issuer have an 'effectively non-contingent obligation' to provide 'financial benefits' as interst payments from the time that a change in the interest rate could take effect?
NATIONAL INSTITUTE OF ACCOUNTANTS
INSTITUTE OF CHARTERED ACCOUNTANTS
TAXATION INSTITUTE OF AUSTRALIA