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INCOME TAX ASSESSMENT ACT 1997 - SECT 880.110

Sovereign entity's deduction from membership interest etc.--loss not deductible

    A * sovereign entity cannot deduct an amount if:

  (a)   the sovereign entity is covered by section   880 - 125; and

  (b)   the amount is a loss in respect of any of the following kinds of interest that the sovereign entity holds in another entity:

  (i)   a * membership interest;

  (ii)   a * debt interest;

  (iii)   a * non - share equity interest; and

  (c)   the requirements in paragraphs 880 - 105(1)(c), (d) and (e) would be satisfied, on the assumptions that:

  (i)   the amount were * ordinary income or * statutory income; and

  (ii)   the amount became ordinary income or statutory income of the sovereign entity at the time it arose; and

  (iii)   references in those paragraphs to the test entity were references to the other entity mentioned in paragraph   (b) of this section.



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