This TD, issued on Wed 23.1.2013, states that where a taxpayer enters into a limited recourse loan (investment loan) which is made under a capital protected borrowing for the purposes of Div 247 of the ITAA 1997, and a full recourse loan (interest loan) is entered into solely to fund an amount of prepaid interest on the investment loan, the interest incurred on the interest loan will not be denied deductibility as a consequence of Div 247.
The TD was previously issued as Draft Taxation Determination TD 2012/D10 and is the same.
DATE OF EFFECT: Applies to years of income commencing both before and after its date of issue.
[LTN 15, 23/1/13]