| Disclaimer This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law. 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 your private ruling
Authorisation Number: 1012464299732
This edited version of your ruling will be published in the public register of private binding rulings after 28 days from the issue date of the ruling. The attached private rulings fact sheet has more information.
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Ruling
In order to protect the privacy and commercial in-confidence components of this private binding ruling, the following summary is provided.
The taxpayer entered into a commercial agreement. The Commissioner ruled that:
· The amounts to be received under the commercial agreement are assessable income under section 6-5 of the ITAA 1997.
· The amounts to be paid under the commercial agreements are allowable deductions under section 8-1 of the ITAA 1997.