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Edited version of your written advice
Authorisation Number: 1012718598446
Ruling
Subject: Sustainable Rural Water Use and Infrastructure Program
The Commissioner has ruled on whether:
1. an entity is a participant in a Sustainable Rural Water Use and Infrastructure Program agreement for the purposes of section 59-65 of the Income Tax Assessment Act 1997 (ITAA 1997)
2. a transaction will constitute the disposal of a capital gains tax asset (CGT event A1)
3. section 26-100 of the ITAA 1997 will be satisfied such that expenditure is not deductible
4. section 116-30 of the ITAA 1997 will apply to treat an entity as having received market value
5. section 112-20 of the ITAA 1997 will apply to modify the cost base of an asset to the equivalent market value, and
6. amounts will be non-assessable non-exempt income.
Relevant legislative provisions
Section 6-23 of the Income Tax Assessment Act 1997
Section 26-100 of the Income Tax Assessment Act 1997
Division 59 of the Income Tax Assessment Act 1997
Section 104-10 of the Income Tax Assessment Act 1997
Section 112-20 of the Income Tax Assessment Act 1997
Division 116 of the Income Tax Assessment Act 1997
Division 118 of the Income Tax Assessment Act 1997
Section 124-1105 of the Income Tax Assessment Act 1997
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