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ATO cracks down on split loan arrangements

The Commissioner of Taxation yesterday issued Taxation Determination TD 2012/1 (Determination) in relation to split loans structures described as ‘investment loan interest payment’ arrangements. The Determination had previously been issued as a draft determination.

The Determination discusses the ATO’s views regarding the potential application of Part IVA of the Income Tax Assessment Act 1936 (Cth) to ‘investment loan interest payment’ arrangements.

Part IVA contains the general anti-avoidance rules designed to prevent taxpayers obtaining tax benefits from blatant, artificial or contrived tax avoidance schemes. More…