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Legislation
ATO documents that consider ITAA 1997 s 974-5(4)
7 documents
Income tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997, if the issuer of an interest bearing instrument can change the rate of interest that will become payable to any rate (including zero) that it chooses at its sole discretion, does the issuer have an 'effectively non-contingent obligation' to provide 'financial benefits' as interest payments from the time that a change in the interest rate could take effect?
Income tax: Keybridge Capital Ltd: return of capital and issue of Convertible Redeemable Promissory Notes
Interest free loan to private company repayable if shareholding is sold or the company is sold: application of the debt-equity interest provisions
Debt/Equity Interest: Redeemable Preference Shares - equity interest
Debt/Equity: whether redeemable preference shares are an equity interest or a debt interest
Income tax: for the purposes of Division 974 of the Income Tax Assessment Act 1997, if the issuer of an interest bearing instrument can change the rate of interest that will become payable to any rate (including zero) that it chooses at its sole discretion, does the issuer have an 'effectively non-contingent obligation' to provide 'financial benefits' as interest payments from the time that a change in the interest rate could take effect?
Debt/Equity: whether perpetual convertible notes are an equity interest or a debt interest