Published on 08 Feb 08
by THE TAX INSTITUTE
A joint professional body submission sent to the ATO in relation to the draft taxation ruling TR 2007/D11 - Income tax: debt/equity - identification of any 'effectively non-contingent obligation' of an issuer of a convertible note to provide 'financial benefits' for the purpose of Division 974 of the Income Tax Assessment Act 1997 if the note can be converted at any time at the issuer's discretion into shares that are equity interests in the issuer company.
NATIONAL INSTITUTE OF ACCOUNTANTS
TAXATION INSTITUTE OF AUSTRALIA