New Business Tax System (Debt and Equity) Act 2001 (163 of 2001)

Schedule 1   Debt and equity interests

Part 2   Amendment of the Income Tax Assessment Act 1936

Income Tax Assessment Act 1936

105   After paragraph 177EA(19)(d)

Insert:

(da) if the scheme involves the issue of a non-share equity interest to which section 160APAAAA applies - whether the company has issued, or is likely to issue, equity interests in the company:

(i) that are similar, from a commercial point of view, to the non-share equity interest; and

(ii) dividends in respect of which are frankable;