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Edited version of private ruling
Authorisation Number: 1011659207252
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Ruling
Subject: Capital Raising
Question 1
Will the distributions to be paid in respect of the securities be a frankable distribution pursuant to Subdivision 202-C of the Income Tax Assessment Act 1997 (ITAA 1997)?
The following advice was provided.
No. The distributions to be paid in respect of the securities will not be a frankable distribution pursuant to Subdivision 202-C of the ITAA 1997.
Question 2
Will the arrangements give rise to the application of section 204-15 of the ITAA 1997?
The following advice was provided.
No. The arrangements will not give rise to the application of section 204-15 of the ITAA 1997.
Question 3
Will the arrangements give rise to the application of section 204-30 of the ITAA 1997?
The following advice was provided.
No. The arrangements will not give rise to the application of section 204-30 of the ITAA 1997.
Question 4
Will the paid up value of the security be included in the adjusted average equity capital of the entity pursuant to Division 820 of the ITAA 1997?
The following advice was provided.
Yes, the paid up value of the security will be included in the adjusted average equity capital of the entity pursuant to Division 820 of the ITAA 1997 to the extent they are issued and fully paid.