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Edited version of your private ruling
Authorisation Number: 1012613248218
Ruling
Subject: Part IVA
Question 1
Will the Commissioner confirm that no determination will be made pursuant to section 177F of the Income Tax Assessment Act 1936 (ITAA 1936) to cancel the whole or part of any tax benefit that might be obtained in connection with the Scheme under a postulate?
Answer
Yes.
Relevant legislative provisions
Income Tax Assessment Act 1936 Section 177D
Income Tax Assessment Act 1936 Section 177F
Reasons for decision
Having regard to the eight matters in subsection 177D(2) of the ITAA 1936, the Commissioner does not consider that any party to the Scheme entered into the Scheme for the sole or dominant purpose of obtaining a tax benefit.
Accordingly, the Commissioner will not make a determination pursuant to section 177F of the ITAA 1936 to cancel the whole or part of any tax benefit that might be obtained in connection with the Scheme.
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