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Edited version of your private ruling
Authorisation Number: 1012560531179
Ruling
Subject: Proposed Implementation Steps
Question 1
Will CGT event A1 (section 104-10 of the Income Tax Assessment Act 1997 (ITAA 1997)) happen?
Answer
No
Question 2
Will CGT event E1 (section 104-55 of the ITAA 1997) happen?
Answer
No
Question 3
Will CGT event A1 (section 104-10 of the ITAA 1997) happen?
Answer
No
Question 4
Will CGT event E1 (section 104-55 of the ITAA 1997) happen?
Answer
No
Question 5
Will CGT event A1 (section 104-10 of the ITAA 1997) happen?
Answer
Yes
This ruling applies for the following periods:
1 July 2013 to 30 June 2014
The scheme commences on:
1 July 2013
Relevant facts and circumstances
HeadCo is planning on entering into a transaction. As part of the transaction, a number of steps need to be implemented. One of these steps is to obtain the approval of the shareholders in the various Sub-Cos to vary their respective Constitutions.
Relevant legislative provisions
Income Tax Assessment Act 1997 Part 3-1
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