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Edited version of your written advice
Authorisation Number: 1012822478482
Date of advice: 15 June 2015
Ruling
Subject: Internal reorganisation
The taxpayer asked for a private ruling in respect of a proposed internal reorganisation. The Commissioner has ruled on each of the questions in the private ruling application.
Relevant facts and circumstances
Company A, an Australian resident, is a wholly owned by F Co which is a foreign resident.
Company A disposes its foreign subsidiaries to F Co as part of a corporate restructure.
Relevant legislative provisions
Income Tax Assessment Act 1936 section 45B;
Income Tax Assessment Act 1936 Part IVA;
Income Tax Assessment Act 1997 Subdivision 768-G; and
Income Tax Assessment Act 1997 Division 802.
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