| Disclaimer This edited version has been archived due to the length of time since original publication.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: 1012865765637
Date of advice: 16 September 2015
Ruling
Subject: International restructure
Company A is a company incorporated in Australia. It wants to rationalise its group structure so
that it can hold shares in certain overseas subsidiaries directly.
The Commissioner issued a Private Ruling on sections 126-50, 104-135, 768-5 and 768-505, and
subsection 995-1(1), of the ITAA 1997.
This ruling applies for the following periods:
1 July 2015 to 30 June 2016
Relevant legislative provisions
Income Tax Assessment Act 1997 section 126-50
Income Tax Assessment Act 1997 section 104-135
Income Tax Assessment Act 1997 section 768-5
Income Tax Assessment Act 1997 section 768-505
Income Tax Assessment Act 1997 subsection 995-1(1)
Copyright notice
© Australian Taxation Office for the Commonwealth of Australia
You are free to copy, adapt, modify, transmit and distribute material on this website as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).
