2.49.1  General principle

In addition to determining its preferred equity capital structure and debt funding structure, the private sector also frequently uses structured financing, including a securitised licence structure, to derive additional economic efficiency, including tax efficiency, from its PPP delivery structure. Provided that the private sector obtains appropriate tax rulings from the Australian Tax Office and DTF agrees to the proposed drafting to give effect to the structured financing solution, the State is neutral in relation to whether a structured financing solution is used.