• Commissioner's power

    Where an arrangement involves, broadly:

    • an effectively non contingent obligation to provide a financial benefit which equals a substantial part of the financial benefit received
    • the provision of contingent, but likely, financial benefits that, when combined with the effectively non contingent payments, are expected to equal or exceed the financial benefit received
    • the Commissioner can determine that the arrangement gives rise to a debt interest.
      Last modified: 18 Jan 2017QC 36047