Income tax: can section 177EA of the Income Tax Assessment Act 1936 apply to the issue of 'dollar value' convertible notes of the type described in this Taxation Determination?
1
Draft Taxation Determination TD 2007/D16 considered the potential application of section 177EA of the Income Tax Assessment Act 1936 to a particular type of convertible note that has certain features, including a 'dollar value' conversion mechanism (that are explained in the draft Determination).
2
TD 2007/D16 is being replaced by TR 2008/D8. To the extent that our views in TD 2007/D16 still apply, they have been incorporated into TR 2008/D8 which issued today.