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Edited version of private advice
Authorisation Number: 1052104051752
Date of advice: 10 May 2023
Ruling
Subject: Deductions for dividends on-paid to non-resident owner
The Commissioner has determined that, based on the arrangement in the present case, each of the conditions in paragraphs 46FA(1)(a) to (g) of the Income Tax Assessment Act 1936 (ITAA 1936)will be satisfied.
As such, the resident company will be entitled to a deduction under section 46FA of the ITAA 1936.
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