AUSTRALIAN TAXATION OFFICE: Draft Taxation Determination -- TD 1999/D19.

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M2 PRESSWIRE-1 February 1999-AUSTRALIAN TAXATION OFFICE: Draft Taxation Determination -- TD 1999/D19 (C)1994-99 M2 COMMUNICATIONS LTD RDATE:270199 * FOI status: draft only - for comment Income tax: interest withholding tax exemption under section 128F of the Income Tax Assessment Act 1936 - does the exemption from interest withholding tax in section 128F extend to payments made by a guarantor to a lender on behalf of a borrower who defaults? 1.

Yes. Payments made on behalf of a company by a guarantor to a lender constitute 'interest' for the purposes of Division 11A. Therefore, where a liability to pay withholding tax arises under section 128B, the exemption from interest withholding tax in section 128F is available to such payments (provided the other...