Going out on a Second Limb - An Analysis of the Deductibility of Interest by Recognising a Distinction between the Positive Limbs of s 51(1)

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.