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This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law.

You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4.

Edited version of your written advice

Authorisation Number: 1012727703831

Ruling

Subject: Tax treatment of gains on certain forward contracts under the Taxation of Financial Arrangements

In order to protect the privacy of this taxpayer and the commercial in-confidence components of this arrangement, the Edited Version of this private ruling is prepared in the following form.

This ruling concerns the tax treatment of gains in respect of this particular taxpayer's certain forward contracts under TOFA hedging rules in Subdivision 230-E of the ITAA 1997.

This ruling applies for the following periods:

A number of income years

The scheme commences on:

During the 2014 income year

Relevant legislative provisions

Income Tax Assessment Act 1997 Section 230-45

Income Tax Assessment Act 1997 Section 230-310

Income Tax Assessment Act 1997 Section 230-315

Income Tax Assessment Act 1997 Section 230-325

Income Tax Assessment Act 1997 Section 230-330

Income Tax Assessment Act 1997 Section 230-335

Income Tax Assessment Act 1997 Section 230-355

Income Tax Assessment Act 1997 Section 230-360

Income Tax Assessment Act 1997 Section 230-365

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