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Edited version of your written advice
Authorisation Number: 1012997074923
Date of advice: 13 April 2016
Ruling
Subject: Infrastructure Securitisation Transaction - TOFA and Thin Capitalisation
Question 1
Will the accruals method under section 230-100 of the ITAA 1997 apply to the financial arrangements between SecureCo and the Government?
Answer
Yes.
Question 2
Will the allocation of gains arising from the financial arrangement between SecureCo and the Government using the compounding accruals method satisfy the requirements of paragraph 230-135(2)(a) of the ITAA 1997?
Answer
Yes.
Question 3
Will SecureCo be entitled to an exemption under section 820-39 of the ITAA 1997 from any debt deduction being disallowed under Division 820 of the ITAA 1997?
Answer
Yes.