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This edited version has been archived due to the length of time since original publication.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.

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Edited version of your written advice

Authorisation Number: 1051314562925

Date of advice: 12 December 2017

Ruling

Subject: Non-cash business benefit

In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided.

The taxpayer sought a ruling in regards to section 21A of the Income Tax Assessment Act 1936 (ITAA 1936). The Commissioner ruled that the asset acquired by the taxpayer constituted a ‘non-cash business benefit’ under section 21A of the ITAA 1936 as it was income derived by the taxpayer and that the benefit shall be brought into account at its arms-length value reduced by the recipient’s contribution.

Relevant legislative provisions

Section 21A of the ITAA 1936


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