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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 private advice

Authorisation Number: 1052409036762

Date of advice: 23 June 2025

Ruling

Subject: Capital raising

In order to protect the privacy of this taxpayer and the commercial in-confidence components of this scheme, the Edited Version is prepared in the following form.

The ruling relates to a scheme that the taxpayer entered into and concerns the following provisions of the income tax legislation:

Section 26BC of the Income Tax Assessment Act 1936

Part IVA of the Income Tax Assessment Act 1936

Subsection 177A(5) of the Income Tax Assessment Act 1936

Subsection 177D(1) of the Income Tax Assessment Act 1936

Subsection 177D(2) of the Income Tax Assessment Act 1936

Section 177F of the Income Tax Assessment Act 1936

Paragraph 177F(1)(a) of the Income Tax Assessment Act 1936

Paragraph 177F(1)(c) of the Income Tax Assessment Act 1936

Section 100-45 of the Income Tax Assessment Act 1997

Section 102-5 of the Income Tax Assessment Act 1997

Section 102-10 of the Income Tax Assessment Act 1997

Section 102-15 of the Income Tax Assessment Act 1997

Section 108-5 of the Income Tax Assessment Act 1997

Section 121-20 of the Income Tax Assessment Act 1997

Subsection 121-20(1) of the Income Tax Assessment Act 1997

Subsection 121-20(2) of the Income Tax Assessment Act 1997

Subsection 121-20(3) of the Income Tax Assessment Act 1997

Subsection 121-20(4) of the Income Tax Assessment Act 1997

Subsection 121-20(5) of the Income Tax Assessment Act 1997

Section 121-25 of the Income Tax Assessment Act 1997

Section 216-30 of the Income Tax Assessment Act 1997

Section 295-385 of the Income Tax Assessment Act 1997

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