Product Ruling

PR 2001/163W

Income tax: deductibility of interest incurred on borrowings under the UBS Warburg Protected Equity Product

  • Please note that the PDF version is the authorised version of this withdrawal notice.
    This document incorporates revisions made since original publication. View its history and amending notices, if applicable.

FOI status:

may be released

Preamble

The number, subject heading, and the What this Product Ruling is about (including Tax law(s), Class of persons and Qualifications sections), Date of effect, Withdrawal, Arrangement and Ruling parts of this document are a 'public ruling' in terms of Part IVAAA of the Taxation Administration Act 1953. Product Ruling PR 1999/95 explains Product Rulings and Taxation Rulings TR 92/1 and TR 97/16 together explain when a Ruling is a public ruling and how it is binding on the Commissioner.

Withdrawal

1. This Product Ruling is withdrawn and ceases to have effect after 31 December 2004. The Ruling continues to apply, in respect of the tax laws ruled upon, to all persons within the specified class who enter into the specified arrangement during the term of the Ruling. Thus, the Ruling continues to apply to those persons, even following its withdrawal, who entered into the specified arrangement prior to withdrawal of the Ruling. This is subject to there being no material difference in the arrangement or in the persons' involvement in the arrangement.

Commissioner of Taxation
19 December 2001

Not previously issued in draft form

References

ATO references:
NO T2001/007040

ISSN: 1441-1172

Related Rulings/Determinations:

PR 2001/80
PR 1999/95
TR 92/1
TR 92/20
TR 97/11
TR 97/16
TD 93/34
TR 95/33
TR 98/22

Subject References:
financial products
interest expenses
prepaid expenses
product rulings
public rulings
STS taxpayer
taxation administration
tax avoidance

Legislative References:
ITAA 1997 8-1
ITAA 1997 Div 108 Part 3-1
ITAA 1997 Div 110 Part 3-1
ITAA 1997 Div 328 Part 3-45
ITAA 1936 Part IVA
ITAA 1936 51AAA
ITAA 1936 82KL
ITAA 1936 82KZL(2)(a)
ITAA 1936 82KZM
ITAA 1936 82KZMA
ITAA 1936 82KZMB
ITAA 1936 82KZMC
ITAA 1936 82KZME

PR 2001/163W history
  Date: Version: Change:
  19 December 2001 Original ruling  
  17 December 2003 Consolidated ruling Addendum
You are here 1 January 2005 Withdrawn  

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