| Disclaimer This edited version has been archived due to the length of time since original publication.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: 1013070223203
Date of advice: 15 August 2016
Ruling
Subject: Division 197 - tainted share capital accounts
Question 1
Will any of the Proposed Accounting Entries constitute a transfer to which section 197-5 of the Income Tax Assessment Act 1997 (ITAA 1997) applies?
Answer
No.
Question 2
If the answer to Question 1 is yes, will the exclusion in section 197-10 of the ITAA 1997 apply to the transfer?
Answer
Not applicable.
This ruling applies for the following period:
XX/XX/XXXX to XX/XX/XXXX
The scheme commences on:
XX/XX/XXXX
Relevant facts and circumstances
The taxpayer, applied for a ruling in relation to proposed accounting entries. Relevant facts and documents were submitted.
Relevant legislative provisions
Income Tax Assessment Act 1997 section 197-5
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).
