Lenders are hoping the market for self-managed superannuation fund loans will gather some much needed momentum following the release of an Australian Taxation Office ruling that provides greater clarity about the tax treatment of the product.The ruling explains key concepts, such as the meaning of a "single acquirable asset", the difference between repairs and improvements, and how the ATO looks at the question of when an asset has been changed to such an extent that it is a different asset.These are all issues that have caused problems for SMSF trustees and their advisers, and have deterred many trustees from using gearing in their funds.Super funds have only been allowed to borrow since 2007 and the rules governing SMSF loans have been a rather tortured work in progress ever since.Industry representatives welcomed last month's ruling, SMSFR 2012/1. The chief executive of the SMSF Professionals' Association of Australia, Andrea Slattery, said: "The ruling has brought some clear thinking to issues surrounding borrowing by self-managed funds."Lenders say the market is getting more competitive, with more brokers and advisers inquiring about SMSF loans. More lenders are entering the market and costs are coming down.Last month, Liberty Financial cut the rate on its SuperCredit loan to 6.99 per cent, which is comparable with a standard mortgage rate. Liberty charges a A$695 set-up fee.Liberty's general manager of commercial finance, Suresh Pillai, said the group has had the loan in the market since 2010 and is writing about $10 million worth of business a month. Borrowers can use residential or commercial property as security.Pillai said: "When we got into the market there wasn't much competition. Rates were high and loans were expensive to set up. "The market is evolving and the latest tax ruling, which provides a lot more clarity, will help."ING Direct entered the SMSF loan market in September last year with a white label product that has been take up by three of the bank's 15 mortgage managers - AFG, Homeloans and Australian Financial.ING Direct's head of mortgage management, Laurie Shaw, said five more managers were preparing to offer the loan. The loan can only be used to purchase residential property. Shaw said a commercial property loan would be launched in the next few months. He said SMSF loans made up about six per cent of new white label loans. Shaw said: "The ATO ruling does clarify things. The other thing that will give the market impetus is the cap on superannuation contributions. Financial planners are looking for new ways to boost their clients' super account balances and geared investments do not count towards the cap."What makes SMSF gearing tricky is that trustees may borrow only to acquire "a single acquirable asset".The head of technical services at MLC, Gemma Dale, said: "If the super fund uses borrowed funds to acquire vacant land, the land is the single acquirable asset. If you put a building on it you have to treat that as another asset. The rules do not allow for a single loan to fund