Product Ruling

PR 2002/41W

Income tax: deductibility of interest incurred on borrowings under the Commonwealth Bank Protected Portfolio Loan

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FOI status:

May be released

Preamble

The number, subject heading, and the What this Product Ruling is about (including Tax laws, Class of persons and Qualifications sections), Date of effect, Withdrawal, Previous Ruling, 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 This Product Ruling is withdrawn and ceases to have effect after 30 June 2005. 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
24 April 2002

Not previously released in draft form

References

ATO references:
NO T2002/000602

ISSN: 1441 1172

Related Rulings/Determinations:

PR 1999/95
TR 92/1
TR 92/20
TR 95/33
TR 97/16
TD 93/34

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

Legislative References:
ITAA 1936 51AAA
ITAA 1936 82KL
ITAA 1936 82KZL(1)
ITAA 1936 82KZL(2)(a)
ITAA 1936 82KZM
ITAA 1936 82KZMA
ITAA 1936 82KZMB
ITAA 1936 82KZMC
ITAA 1936 82KZMD
ITAA 1936 82KZME
ITAA 1936 82KZME(4)
ITAA 1936 82KZME(5)
ITAA 1936 82KZME(5)(b)(iii)
ITAA 1936 82KZMF
ITAA 1936 Subdiv H of Div 3 Pt III
ITAA 1936 Pt IVA
ITAA 1997 8-1
ITAA 1997 Div 108 Pt 3-1
ITAA 1997 Div 110 Pt 3-1
ITAA 1997 110-25(2)
ITAA 1997 Div 328 Pt 3-45
ITAA 1997 Subdivision 328-F
ITAA 1997 Subdivision 328-G
Copyright Act 1968

PR 2002/41W history
  Date: Version: Change:
  24 April 2002 Original ruling  
You are here 1 July 2005 Withdrawn