Application of the debt/equity rules to a related party 'at call' loan until 30 June 2005

The debt/equity rules are used to determine whether a scheme gives rise to a debt or an equity interest for tax purposes. These rules generally apply from 1 July 2001.

There are, however, transitional rules for 'at call' loans. These transitional rules deem 'at call' loans made on or before 30 June 2005 to a company by a connected entity, to be debt interests.

    Last modified: 13 Feb 2006QC 18207