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Edited version of your written advice
Authorisation Number: 1012787267578
Ruling
Subject: Capital raising
Question 1
Will the Instruments be characterised as 'equity interests' for the purposes of Division 974 of the Income Tax Assessment Act 1997 (ITAA 1997)?
Answer
Yes
Question 2
Will dividends payable in respect of the Instruments constitute frankable distributions under section 202-40 of the ITAA 1997 and not be unfrankable under section 202-45 of the ITAA 1997?
Answer
Yes
Question 3
Will section 204-30 of the ITAA 1997 apply to the scheme consisting of the issue of the Instruments?
Answer
No
Question 4
Will section 177EA of the Income Tax Assessment Act 1936 apply to the scheme consisting of the issue of the Instruments?
Answer
No