Macquarie Finance Limited v Commissioner of Taxation

• 1. Income Tax
  2. › Deductions
  3. › Interest payments
  4. › Whether incurred in gaining or producing assessable income
  5. › Whether necessarily incurred in business for gaining or producing assessable income
  6. › Stapled securities issued as part of corporate group capital raising
  7. › Role of purpose of expenditure in characterisation
  8. › Objective purpose versus subjective purpose
  9. › Income Tax Assessment Act 1997 (Cth), s 8-1
• 1. Income Tax
  2. › Deductions
  3. › Capital or revenue distinction
  4. › Interest on debenture notes issued as part of Tier 1 capital raising
  5. › Whether payments of a capital nature
  6. › Arrangements qualifying as Tier 1 capital under APRA prudential standards
  7. › Income Tax Assessment Act 1997 (Cth), s 8-1
• 1. Income Tax
  2. › Anti-avoidance
  3. › Part IVA
  4. › Dominant purpose
  5. › Whether dominant purpose of obtaining tax benefit
  6. › Capital raising involving hybrid debt/equity instruments
  7. › Alternative postulate
  8. › Commercial advantages of debt financing
  9. › Income Tax Assessment Act 1936 (Cth), ss 177A, 177C, 177D, 177F

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