Product Ruling

PR 1999/1W

Income tax: Hillston Grove Vineyards Project

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FOI status:

Notice of Withdrawal

Product Ruling PR 1999/1 is withdrawn with effect from today.

We have reviewed the Hillston Grove Vineyards Project and determined that the arrangement, as implemented, is materially different on a number of grounds from that described in the Ruling, including:

1.

the Project used unfunded bridging finance for a significant number of investors, not disclosed in the application for the Product Ruling;

2.

the services performed by the parties to the Project were not in accordance with those described in the arrangement;

3.

consideration for entering a number of management agreements was not in accordance with that described in the arrangement; and

4.

some investors have been forgiven amounts in a manner not disclosed in the application for the Product Ruling.

As a result there is no class of persons to whom the Ruling applies.

Commissioner of Taxation
9 August 2000

References

ATO references:
NO T2000/4313

Related Rulings/Determinations:

PR 1998/1
TR 92/1
TR 97/11
TR 97/16
TD 93/34

Subject References:
carrying on a business
commencement of business
fee expenses
interest expenses
management fees expenses
primary production
primary production expenses
producing assessable income
product rulings
public rulings
schemes and shams
taxation administration
tax avoidance
tax benefits under tax avoidance schemes
tax shelters
tax shelters project

Legislative References:
ITAA36 82KL
ITAA36 82KZM
ITAA36 Pt IVA
ITAA36 177A
ITAA36 177C
ITAA36 177D
ITAA97 8-1