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Edited version of your written advice
Authorisation Number: 1012678777983
Ruling
Subject: Subdivision 124-M Rollover
Question 1
Will Shareholder 1 be regarded as a significant stakeholder or common stakeholder pursuant to section 124-783 of the Income Tax Assessment Act 1997 (ITAA 1997)?
Answer
Yes
Question 2
If the answer to question 1 is yes, is the arrangement described in question 1 a restructure for the purpose of section 124-784A of the ITAA 1997?
Answer
Yes
Question 3
Will any of the following Shareholders (x8) be regarded as a significant stakeholder or common stakeholders pursuant to section 124-783 of the ITAA 1997?
Answer
No
Question 4
If the answer to question 3 is yes, is the arrangement a restructure for the purpose of section 124-784A of the ITAA 1997?
Answer
No
Question 5
Will the first element of the cost base and reduced cost base of Replacement Entity in the Original Entity shares it acquires from Shareholder 1 be determined pursuant to subsection 124-782(1) of the ITAA 1997?
Answer
Yes
Question 6
Will the first element of the cost base and reduced cost base of Replacement Entity in the Original Entity shares it acquires from the Shareholders (x8) be determined pursuant to Divisions 110 and 112 of the ITAA 1997?
Answer
Yes
This ruling applies for the following periods:
year ended 30 June 20xx
The scheme commences on:
during the year ended 30 June 20xx
Relevant facts and circumstances
The taxpayer, the Replacement Entity, applied for a private ruling in connection with a corporate group restructure under which the Replacement Entity is interposed between the Original Entity and its shareholders.
Relevant legislative provisions
Income Tax Assessment Act 1997
Subdivision 124-M
Division 110
Division 112