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This edited version has been archived due to the length of time since original publication.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: 1051322192544

Date of advice: 21 December 2017

Ruling

Subject: Deductibility of expenditure, capital gains tax and the application of Part IVA

The ruling relates to an arrangement that the taxpayer entered into concerning a vertically integrated business that included mining operations, the deductibility of associated expenditure, capital gains tax, and the following provisions of the income tax legislation:

Income Tax Assessment Act 1936 Part IVA

Income Tax Assessment Act 1997 Section 8-1

Income Tax Assessment Act 1997 Section 40-25

Income Tax Assessment Act 1997 Section 40-30

Income Tax Assessment Act 1997 Section 40-40

Income Tax Assessment Act 1997 Section 40-85

Income Tax Assessment Act 1997 Section 40-185

Income Tax Assessment Act 1997 Section 40-190

Income Tax Assessment Act 1997 Section 40-285

Income Tax Assessment Act 1997 Section 40-295

Income Tax Assessment Act 1997 Section 40-300

Income Tax Assessment Act 1997 Section 40-305

Income Tax Assessment Act 1997 Section 40-735

Income Tax Assessment Act 1997 Section 40-755

Income Tax Assessment Act 1997 Section 104-10

Income Tax Assessment Act 1997 Section 108-5

Income Tax Assessment Act 1997 Section 705-47

Income Tax Assessment Act 1997 Section 705-70

Income Tax Assessment Act 1997 Division 711

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).