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Edited version of your private ruling
Authorisation Number: 1012558996953
Ruling
Subject: Sovereign Immunity
Question
Are the entity and its wholly-owned offshore subsidiary exempt from Australian income tax (including capital gains tax) and withholding tax on their interest income, dividend income, trust distributions and any other income (including any managed investment trust distributions) derived from their minority investment in the special purpose vehicles used to acquire Australian assets under the principle of sovereign immunity?
Answer
Yes
This ruling applies for the following periods:
For the period 1 July 2014 to 30 June 2015
For the period 1 July 2015 to 30 June 2016
For the period 1 July 2016 to 30 June 2017
The scheme commences on:
1 January 2009
Relevant facts and circumstances
The description of the scheme to which this ruling applies incorporates the scheme and assumption as set out in the previous ruling, and information provided in the application for private ruling and further correspondence.
There is only one non-material change to the description of scheme as set out in the previous ruling.
Reasons for decision
As the only change to the scheme as set out in the previous ruling is not material the reasons for decision as outlined in the previous ruling continue to apply.
Therefore, the entity and its wholly-owned offshore subsidiary will be exempt from Australian income tax (including capital gains tax) and withholding tax on their interest income, dividend income, trust distributions and any other income (including any managed investment trust distributions) derived from their minority investment in the special purpose vehicles used to acquire Australian assets under the principle of sovereign immunity.
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