| Disclaimer This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law. You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4. |
Edited version of private ruling
Authorisation Number: 1011762520777
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Ruling
Subject: Loan facility agreement
What this ruling is about:
In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided.
The taxpayer entered into a loan facility agreement.
The Commissioner ruled that:
· Certain amounts received by the taxpayer will not be assessable to the taxpayer
· Certain amounts received by the parties to the loan facility agreement will not be assessable to the taxpayer under section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997) or other relevant statutory income provisions
· Division 230 of the ITAA 1997 will not apply to this loan facility agreement; and
· Part IVA of the Income Tax Assessment Act 1936 will not apply to the arrangement.