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Edited version of private advice
Authorisation Number: 1051550908238
Date of advice: 30 July 2019
Ruling
Subject: Debt Note
Question 1
Will each of the coupons payable under the Note at the higher interest rate be wholly deductible to Entity X under subsection 230-15(2) of the Income Tax Assessment Act 1997?
Answer
No
Question 2
If the answer to Question 1 is No, will only a portion of the coupons payable under the Note at the higher interest rate be deductible to Entity X under subsection 230-15(2) of the Income Tax Assessment Act 1997, with any balance not being deductible?
Answer
Yes
Question 3
Will each coupon payable under the Note at the lower interest rate be wholly deductible to Entity X under subsection 230-15(2) of the Income Tax Assessment Act 1997?
Answer
Yes
Question 4
Will each coupon payable under the Note be deductible to Entity X under subsection 230-15(2) of the Income Tax Assessment Act 1997 in accordance with subsection 230-15(5) of the Income Tax Assessment Act 1997?
Answer
No
Relevant facts and circumstances
The taxpayer (Entity X) applied for a private ruling on the tax consequences, pursuant to Division 230 of the Income Tax Assessment Act 1997, arising from issuing a Note.
Relevant legislative provisions
Income Tax Assessment Act 1997 Division 230
Income Tax Assessment Act 1997 subsection 230-15(2)
Income Tax Assessment Act 1997 subsection 230-15(4)
Income Tax Assessment Act 1997 subsection 230-15(5)
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