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  • 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: 16 Apr 2018QC 36047