Income tax: tax consequences of investing in the Commonwealth Bank Protected Portfolio Loan

Product Ruling PR 2005/78 sets out the Commissioner's view on the income tax consequences for entities participating in the Commonwealth Bank Protected Portfolio Loan (the 'PPL').

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 capital protection for entities in the PPL. PR 2005/78 therefore has no application to entities entering into the PPL on or after 1 July 2007.