Legislation

TAA 1953 s 832-725(1)(h) 61 Matters in subsection 832-725(2) 63 Matter (a) - the facts and circumstances that exist in relation to the scheme 64 Example 2 - matter (a) 68 Matter (b) - the source of the funds used by the interposed foreign entity (the payee) to provide the entity (the payer) with the loan or other debt interest (in respect of which the interest payment is made) 71 Matter (c) - whether the interposed foreign entity (the payee) engages in substantial commercial activities in carrying on a banking, financial or other similar business 75 Example 3 - matter (c) 81 Example 4 - matter (c) 87 Interaction of matters taken into account 91 Exception for CFC regimes 93 Back-to-back arrangements 95 Relying on this Ruling This publication is a public ruling for the purposes

ATO documents that consider TAA 1953 s 832-725(1)(h) 61 Matters in subsection 832-725(2) 63 Matter (a) - the facts and circumstances that exist in relation to the scheme 64 Example 2 - matter (a) 68 Matter (b) - the source of the funds used by the interposed foreign entity (the payee) to provide the entity (the payer) with the loan or other debt interest (in respect of which the interest payment is made) 71 Matter (c) - whether the interposed foreign entity (the payee) engages in substantial commercial activities in carrying on a banking, financial or other similar business 75 Example 3 - matter (c) 81 Example 4 - matter (c) 87 Interaction of matters taken into account 91 Exception for CFC regimes 93 Back-to-back arrangements 95 Relying on this Ruling This publication is a public ruling for the purposes