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Edited version of your written advice
Authorisation Number: 1012798827380
Ruling
Subject: Thin capitalisation exemption
The Commissioner issued a Private Binding Ruling in relation to a financing arrangement. The
Commissioner considered the application of the exemption from the thin capitalisation rules for special purpose entities contained in Division 820 of the Income Tax Assessment Act 1997 (ITAA 1997) pursuant to section 820-39 of the ITAA 1997.