Going out on a second limb - An analysis of the deductibility of interest by recognising a distinction between positive limbs of S51(1)

Abstract

A Taxation Ruling and various cases have recently created debate on the topic of the deductibility of interest. It is submitted in this article that recognising a distinction between non business and business taxpayers as indicated by the two positive limbs of s 51(1) would clarify the determination of whether interest is deductible.