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  • Entered into before 9.30am on 16 April 2003

    When interest is fully deductible

    Based on the decision in Firth v. Federal Commissioner of Taxation, if you entered into your product before 9.30am on 16 April 2003, interest is fully deductible on products entered into before 9.30am on 16 April 2003 if both of the following apply:

    • The capital protection is only provided by way of a limited recourse loan facility.
    • The loan does not separately identify or attach value to the capital protection component.

    See also:

    Other products

    For products that use other methods of capital protection, the tax implications will depend on the specific terms and conditions of the capital protected product. If you need information on capital protected products acquired before 9.30am on 16 April 2003 that are not covered by a product ruling and provide capital protection other than by way of limited recourse loans, you can request a private ruling to gain certainty.

      Last modified: 01 Jul 2021QC 17547