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Edited version of your written advice
Authorisation Number: 1013000819053
Date of advice: 26 April 2016
Ruling
Subject: Issue of product
Question 1
Is there a financial arrangement pursuant to section 230-45 of the ITAA 1997?
Answer
Yes
Question 2
Will the arrangement be treated as a financial arrangement under subsection 230-50(1) of the ITAA 1997?
Answer
No
Question 3
Will the losses from the arrangement be deductible pursuant to subsection 230-15(2) of the ITAA 1997?
Answer
Yes
Question 4
Will the accruals method provided for under subsection 230-100(2) of the ITAA 1997 apply to the gain or losses arising from the financial arrangement?
Answer
Yes
Relevant facts and circumstances
The Taxpayer is seeking to raise funds from the market.
Reasons for decision
Question 1
Is there a financial arrangement pursuant to section 230-45 of the ITAA 1997?
Answer
All of the requisite requirements of the relevant legislation have been satisfied.
Question 2
Will the arrangement be treated as a financial arrangement under subsection 230-50(1) of the ITAA 1997?
Answer
All of the requisite requirements of the relevant legislation have not been satisfied.
Question 3
Will the losses from the arrangement be deductible pursuant to subsection 230-15(2) of the ITAA 1997?
Answer
All of the requisite requirements of the relevant legislation have been satisfied.
Question 4
Will the accruals method provided for under subsection 230-100(2) of the ITAA 1997 apply to the gain or losses arising from the financial arrangement?
Answer
All of the requisite requirements of the relevant legislation have been satisfied.