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22 Apr 15 Arrangement funding return through connected entities – TD 2015/10

On 22 April 2015 the ATO issued a Taxation Determination entitled “Income tax: will paragraph 974-80(1)(d) of the Income Tax Assessment Act 1997 be satisfied merely because a company has issued a debt interest to a listed property trust within the same stapled property group?”: TD 2015/10.

The determination answers the question in the negative. In the Commissioner's view, the fact that a company has issued a debt interest to a listed property trust within the same stapled property group will not of itself be sufficient to form a conclusion under s 974-80(1)(d) that there is a scheme, or a series of schemes, designed to operate so that the returns on the debt interest are used to fund returns on what is in substance equity held by another person (the “ultimate recipient”).

The determination was previously issued in draft as TD 2014/D20.

The ATO has also published a compendium of responses to the issues raised by external parties to the draft determination: TD 2015/10EC.

 


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