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Edited version of private advice
Authorisation Number: 1012617913863
Ruling
Subject: Demerger
The Commissioner was asked to rule on the following issue:
Will any capital gain or capital loss arising for Company A under CGT event A1 as a result of the transfer of Company B shares to Company A shareholders under the demerger be disregarded pursuant to section 125-155 of the Income Tax Assessment Act 1997 (ITAA 1997)?
The Commissioner has ruled that:
Yes. Any capital gain or capital loss arising for Company A under CGT event A1 as a result of the transfer of Company B shares to Company A shareholders under the demerger will be disregarded pursuant to section 125-155 of the ITAA 1997.
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