Debt/Equity: Redeemable Preference Share

there is no effectively non-contingent obligation on the part of the issuer to repay the investment amount under the RPS (required by paragraph 974-20(1)(c) of the ITAA 1997); and, as a result, 2. it cannot be said that the requirements of paragraph 974-20(1)(d) of the ITAA 1997 will be met (that it is substantially more likely than not that the value of the financial benefit (defined in section 974-160 of the ITAA 1997) provided will equal or exceed the value of the financial benefit received).