Taxation Determination

TD 94/50W

Income tax: are legal fees and other professional fees incurred in relation to the construction of an infrastructure facility able to be financed by infrastructure borrowings under section 159GZZZZA of the Income Tax Assessment Act 1936?

  • Please note that the PDF version is the authorised version of this ruling.
    TD 94/50 has been withdrawn as part of a project to review public rulings.
    This document has changed over time. View its history.

Notice of Withdrawal

Taxation Determination TD 94/50 is withdrawn with effect from today.

1. TD 94/50 explains what types of legal expenses or professional fees could be financed by way of infrastructure borrowings under section 159GZZZZA of the Income Tax Assessment Act 1936 (ITAA 1936).

2. TD 94/50 deals with the former infrastructure borrowing provisions in Division 16L of Part III of the ITAA 1936, which were repealed by the Taxation Laws Amendment (Infrastructure Borrowings) Act 1997.

3. TD 94/50 has no ongoing relevance and is therefore withdrawn without replacement.

Commissioner of Taxation
27 June 2018


You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).


ATO references:
NO 1-D75OWX3

ISSN: 2205-6211

Related Rulings/Determinations:

TD 94/49
TD 94/51
TD 94/52
TD 94/53
IT 2442

Subject References:
architect's fees
engineer's fees
debt establishment fees
development fees
infrastructure borrowing
legal expenses
stamp duty

Legislative References:
ITAA 159GZZZZA(3)(a)

TD 94/50W history
  Date: Version: Change:
  16 June 1994 Original ruling  
You are here 27 June 2018 Withdrawn