TD 2012/19 (non-share equity interest issued at or through a permanent establishment) withdrawn
09 Oct 2014
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'."