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Income tax treatment of Arrangement 1 and Arrangement 2 In order to protect the privacy of the taxpayer and commercial in-confidence components of this private binding ruling, the following summary is provided:

1 Does Arrangement 1 constitute debt interests pursuant to Division 974 of the Income Tax Assessment Act 1997 (ITAA 1997)?

1 Yes. Question 2 Does Arrangement 2 constitute debt interests pursuant to Division 974 of the ITAA 1997? Answer 2 Yes. Question 3 Are Arrangement 1 and Arrangement 2 separate arrangements for the purposes of Division 230 of the ITAA 1997? Answer 3 No. Question 4 Do Arrangement 1 and Arrangement 2 together (Financial Arrangement) constitute a financial arrangement pursuant to Division 230 of the ITAA 1997? Answer 4 Yes. Question 5 If the answer to Question 4 is Yes, are any gains made from the Financial Arrangement assessable to the taxpayer pursuant to subsection 230-15(1) of the ITAA 1997? Answer 5 Yes. Question 6 If the answer to Question 4 is Yes, are any losses made from the Financial Arrangement deductible to the taxpayer pursuant to subsection 230-15(2) of the ITAA 1997? Answer 6 Yes. Question 7 If the answer to Question 6 is Yes, does subsection 230-15(5) of the ITAA 1997 apply to cap the deduction? Answer 7 No.

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