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Draft Taxation Determination

TD 93/D200

Income tax: Offshore Banking Units (OBU) - does the definition of 'borrowing or lending activity' in subsection 121D(2) include gold loans and gold borrowings?

  • Please note that the PDF version is the authorised version of this draft ruling.
    This document has been finalised by TD 93/126.

FOI status:

draft only - for comment

Preamble

Draft Taxation Determinations (TDs) present the preliminary, though considered, views of the ATO. Draft TDs may not be relied on; only final TDs are authoritative statements of the ATO.

1. No. It is quite clear from the wording of subsection 121D(2) of the Income Tax Assessment Act 1936 that a borrowing or lending activity applies only to the borrowing or lending of money.

Commissioner of Taxation
19/8/93

References


BO 93/3707-5

ISSN 1038 - 8982

Subject References:
Offshore Banking
OBUs
borrowing or lending activity
gold loans
gold borrowings

Legislative References:
ITAA 121D(2)


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