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17 Mar 11 Part IVA: converting assessable interest income into non-assessable non-exempt dividends - TD 2011/D2

On 16 March 2011, the ATO released draft Taxation Determination TD 2011/D2 for public comment by 15 April 2011.

Its full title is "Income tax: can Part IVA of ITAA 1936 apply to a scheme designed to convert otherwise assessable interest income into non assessable non-exempt dividends?"

The answer given to the question posed is:

"Yes. Whilst the application of Part IVA of ITAA 1936 to any particular arrangement depends on a careful weighing of all the relevant circumstances, Part IVA is likely to have application to arrangements similar to those described in paragraphs 2 to 6 of this draft Determination."


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