Taxation Determination
TD 98/D17
Income tax: does Taxation Determination TD 94/80 apply to the Land Transport Facilities tax offset?
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Please note that the PDF version is the authorised version of this draft ruling.This document has been finalised by TD 1999/31.
FOI status:
draft only - for commentPreamble
| Draft Taxation Determinations (DTDs) present the preliminary, though considered, views of the Australian Taxation Office. DTDs should not be relied on; only final Taxation Determinations represent authoritative statements by the Australian Taxation Office. |
1. No. TD 94/80 clarifies the operation of section 159GZZZZF of the Income Tax Assessment Act 1936 (the Act). That section modified, in respect of infrastructure borrowings, the statutory scheme contained in subsection 51(1) restricting the allowability of deductions incurred in earning exempt income.
2. TD 94/80 explains the Commissioner's view of how the law works in relation to infrastructure borrowings under the former scheme of tax concessions contained in Division 16L of the Act.
3. TD 94/80 has no application to the Land Transport Facilities tax offset scheme contained in Division 396 of the Income Tax Assessment Act 1997.
Your comments
4. If you wish to comment on this draft Determination, please send your comments by 15 January 1999 to:
| Contact officer details have been removed following publication of the final determination. |
Commissioner of Taxation
25 November 1998
References
ATO references:
NO NAT 98/11495-6
Related Rulings/Determinations:
TD 94/80
Subject References:
infrastructure borrowings
land transport facilities tax offset
Legislative References:
ITAA97 Pt 3-45 Div 396
ITAA36 51(1)
ITAA36 Div 16L
ITAA36 159 GZZZZF
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