Taxation Determination

TD 94/80W

Income tax: is an investor who borrows to fund the purchase price of infrastructure borrowings, entitled to a deduction under subsection 51(1) of the Income Tax Assessment Act 1936 for any interest incurred by the investor for that purpose?

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Notice of Withdrawal

Taxation Determination TD 94/80 is withdrawn with effect from today.

1. TD 94/80 explains that an investor who borrows to fund the purchase price of infrastructure borrowings is entitled to deduct the interest incurred under former subsection 51(1) of the Income Tax Assessment Act 1936 (ITAA 1936).

2. TD 94/80 deals with the former infrastructure borrowing provisions in Division 16L of Part III of the ITAA 1936, which were repealed by the Taxation Laws Amendment (Infrastructure Borrowings) Act 1997.

3. TD 94/80 has no ongoing relevance and is therefore withdrawn without replacement.

Commissioner of Taxation
7 December 2016

© AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA

You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

Previously issued as Draft TD 94/D56

References

ATO references:
NO 1-9N72KXS

Subject References:
infrastructure borrowings;
public infrastructure projects

Legislative References:
ITAA 159GZZZZF