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Edited version of private ruling
Authorisation Number: 1011590451358
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Ruling
YEARS OF INCOME TO WHICH THIS RULING APPLIES:
TAX LAW:
Income Tax Assessment Act 1936 Section 177EA,
Income Tax Assessment Act 1997 Section 202-5,
Income Tax Assessment Act 1997 Section 202-15,
Income Tax Assessment Act 1997 Section 202-20,
Income Tax Assessment Act 1997 Section 202-40,
Income Tax Assessment Act 1997 Section 202-45,
Income Tax Assessment Act 1997 Section 204-30,
Income Tax Assessment Act 1997 Section 215-1,
Income Tax Assessment Act 1997 Section 220-30,
Income Tax Assessment Act 1997 Section 220-35,
Income Tax Assessment Act 1997 Section 220-40,
Income Tax Assessment Act 1997 Section 960-115,
Income Tax Assessment Act 1997 Section 960-130,
Income Tax Assessment Act 1997 Section 974-15,
Income Tax Assessment Act 1997 Section 974-20,
Income Tax Assessment Act 1997 Section 974-30,
Income Tax Assessment Act 1997 Section 974-70,
Income Tax Assessment Act 1997 Section 974-75,
Income Tax Assessment Act 1997 Section 974-110,
Income Tax Assessment Act 1997 Section 974-130,
Income Tax Assessment Act 1997 Section 974-135,
Income Tax Assessment Act 1997 Section 974-150,
Income Tax Assessment Act 1997 Section 974-155,
Income Tax Assessment Act 1997 Section 974-160 and
Income Tax Assessment Act 1997 Section 995-1.
WHAT THIS RULING IS ABOUT:
The ruling concerned:
1. Will the transactions continue to be equity interests in accordance with the meaning of Division 974 of the Income Tax Assessment Act 1997 (ITAA 1997)?
2. Will the imputation provisions of Part 3-6 of the ITAA 1997 apply to the payments?
3. Will the Commissioner make a determination under Subdivision 204-D of the ITAA 1997 in relation to the payments?
4. Will the Commissioner make a determination under section 177EA of the Income Tax Assessment Act 1936 (ITAA 1936) in relation to the payments?
The Commissioner ruled:
1. Will the transactions continue to be equity interests in accordance with the meaning of Division 974 of the ITAA 1997?
Yes.
2. Will the imputation provisions of Part 3-6 of the ITAA 1997 apply to the payments?
Yes.
3. Will the Commissioner make a determination under Subdivision 204-D of the ITAA 1997 in relation to the payments?
No.
4. Will the Commissioner make a determination under section 177EA of the ITAA 1936 in relation to the payments?
No.