Product Ruling

PR 2002/79W

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

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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

9. This Product Ruling is withdrawn and ceases to have effect after 30 June 2005.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
5 June 2002

Not previously issued in draft form.

References

ATO references:
NO T2002/003381

ISSN: 1441 1172

Related Rulings/Determinations:

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

Subject References:
Financial products
interest expenses
prepaid expenses
product rulings
public rulings
small business taxpayer
taxation administration
tax avoidance

Legislative References:
TAA 1953 Part IVAAA
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 82KZME(7)
ITAA 1936 82KZMF
ITAA 1936 82KZMF(1)(b)
ITAA 1936 Subdiv H
ITAA 1936 Div 3, Part III
ITAA 1936 Pt IVA
ITAA 1936 272-105, Schedule 2F
ITAA 1997 8-1
ITAA 1997 110-25(2)
ITAA 1997 Subdiv 328-F
ITAA 1997 Subdiv 328-G

PR 2002/79W history
  Date: Version: Change:
  5 June 2002 Original ruling  
  26 June 2002 Consolidated ruling Addendum
  23 October 2002 Consolidated ruling Addendum
  17 December 2003 Consolidated ruling Addendum
You are here 1 July 2005 Withdrawn