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Product Ruling PR 2006/26 sets out the Commissioner's view on the deductibility of interest incurred on borrowings related to the Merrill Lynch Structured Equity Loan.

From 1 July 2007, the recently enacted Division 247 of the Income Tax Assessment Act 1997 applies a different methodology for calculating the cost of the capital protection for entities in the Merrill Lynch Structured Equity Loan. PR 2006/26 therefore has no application to entities entering into the Merrill Lynch Structured Equity Loan on or after 1 July 2007.