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Edited version of private ruling
Authorisation Number: 1011718534605
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Ruling
Subject: Restructure arrangement
What this ruling is about:
In order to protect the privacy and commercial in confidence components of this private binding ruling the following summary is provided.
The taxpayer, a head company of a consolidated tax group for the purposes of Part 3-90 of the Income Tax Assessment Act 1997, undertook a restructure arrangement of its group.
The Commissioner ruled that:
the restructure would satisfy the requirements for Capital Gains Tax relief; and
Part IVA of the Income Tax Assessment Act 1936 would not apply to the arrangement.
This ruling applies for the following period:
Year ended 30 June 2011