This Determination, issued on Wed 4.6.2014, states that a capital support payments, which have the features outlined in the Determination are of capital nature and are not deductible under s 8-1 of the ITAA 1997.
It also states that such payments are not a losses from a financial arrangement and accordingly are not deductible under ss 230-15(2) and (3) of the ITAA 1997.
In addition, the Determination indicates that such payments are included in the cost base and reduced cost base of the parent’s investment in the subsidiary, and therefore not deductible under s 40-880 of the ITAA 1997.
DATE OF EFFECT: Applies to years of income commencing both before and after its date of issue.
[LTN 106, 4/6/14]