| Disclaimer This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law. You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4. |
Edited version of your private ruling
Authorisation Number: 1012263552169
This edited version of your ruling will be published in the public register of private binding rulings after 28 days from the issue date of the ruling. The attached private rulings fact sheet has more information.
Please check this edited version to be sure that there are no details remaining that you think may allow you to be identified. If you have any concerns about this ruling you wish to discuss, you will find our contact details in the fact sheet.
Ruling
Subject: Application of section 8-1 of the Income Tax Assessment Act 1997 (ITAA 1997)
What this ruling is about:
In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided.
The taxpayer entered into an agreement.
The Commissioner ruled that:
Deductions will not be available to the taxpayer under section 8-1 of the ITAA 1997 for certain loss or outgoings incurred by the taxpayer;
Part IVA of the Income Tax Assessment Act 1936 is not applicable to the arrangement as no part of the outgoing is deductible.
Copyright notice
© Australian Taxation Office for the Commonwealth of Australia
You are free to copy, adapt, modify, transmit and distribute material on this website as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).
