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 withdrawal notice.
  TD 94/50 has been withdrawn as part of a project to review public rulings.
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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Taxation Determination TD 94/50 is withdrawn with effect from today.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deals with the former infrastructure borrowing provisions in Division 16L of Part III of the ITAA 1936, which were repealed by the Taxation Laws Amendment (Infrastructure Borrowings) Act 1997.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 TD 94/50 has no ongoing relevance and is therefore withdrawn without replacement.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

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References

ATO references:
NO 1-D75OWX3

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(1)
ITAA 159GZZZZA(2)
ITAA 159GZZZZA(3)(a)