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Edited version of private ruling
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Ruling
Subject: ESS deferred taxing point
Issue 1
Will Company A have a reporting obligation under paragraph 392-5(1)(b) of Schedule 1 to the TAA 1953 as a consequence of an ESS deferred taxing point occurring upon the vesting of employee share acquisition rights?
Answer:
Yes.
Issue 2
Will Company A have a reporting obligation under paragraph 392-5(1)(b) of Schedule 1 to the TAA 1953 as a consequence of an ESS deferred taxing point occurring as a result of the Transaction in respect of non-vested employee share acquisition rights acquired before 1 July 2009?
Answer:
No.
Issue 3
Will Company A have a reporting obligation under paragraph 392-5(1)(b) of Schedule 1 to the TAA 1953 as a consequence of an ESS deferred taxing point occurring as a result of the Transaction in respect of non-vested employee share acquisition rights acquired on or after 1 July 2009?
Answer:
No.