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17 Dec 14 Non-commercial limited recourse borrowing arrangements

The ATO says that it continues to receive private binding ruling requests about whether related party limited recourse borrowing arrangements (LRBAs) give rise to non-arm’s length income (NALI).

Following consultation with industry, the ATO has released ATOID 2014/39 and ATOID 2014/40 which set out the ATO’s view that the NALI provision applies to the non-commercial LRBAs involving related parties in those cases. However, the ATO says that these ATOIDs should not be seen as concluding that all related-party LRBAs give rise to NALI.

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