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09 Oct 14 TD 2012/19 (non-share equity interest issued at or through a permanent establishment) withdrawn

On 8 October 2014, the ATO withdrew TD 2012/19 (Income tax: when is a non-share equity interest 'issued at or through a permanent establishment' for the purposes of paragraph 215-10(1)(c) of the Income Tax Assessment Act 1997?) with effect from the same day.

The Notice of Withdrawal (TD 2012/19W) states, in part, as follows:

"4...On balance, we no longer consider the view in the determination to represent the better view of the law.

5. The ATO intends to issue a replacement determination in due course. The replacement determination will take a considerably narrower view of the concept of 'issued'."


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