The Commissioner provisionally considers that s 974-80(1)(d) of ITAA 1997 is not satisfied merely because a non-resident entity has chosen to invest indirectly in a debt interest issued by an Australian resident company and there is one or more equity interests interposed between the resident entity and the entity holding the debt interest.
The fact that a non-resident entity has decided to invest indirectly in an Australian resident company through one or more interposed entities, and the final leg in the chain is a debt interest, will not of itself be sufficient to form a conclusion under s 974-80(1)(d) that there is a scheme, or a series of schemes, designed to operate so that the returns on the debt interest are used to fund returns on an equity interest held by another person.
This news story is reprinted from CCH Tax Week
Read more details on Outsourcing Accounts Receivable Financing Companies
The fact that a non-resident entity has decided to invest indirectly in an Australian resident company through one or more interposed entities, and the final leg in the chain is a debt interest, will not of itself be sufficient to form a conclusion under s 974-80(1)(d) that there is a scheme, or a series of schemes, designed to operate so that the returns on the debt interest are used to fund returns on an equity interest held by another person.
This news story is reprinted from CCH Tax Week
Read more details on Outsourcing Accounts Receivable Financing Companies
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