This Draft Determination, which was issued on Wed 17.12.2014, states that the fact a company has issued a debt interest to a listed property trust within the same stapled property group will not of itself be sufficient to form a conclusion under para 974-80(1)(d) of the ITAA 1997 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 (the “ultimate recipient”).
DATE OF EFFECT: When the final Determination is issued, it is proposed to apply both before and after its date of issue.
[LTN 244, 17/12/14]