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Edited version of your written advice
Authorisation Number: 1012727572232
Ruling
Subject: Source of Income
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 proposes to enter into a debt factoring arrangement.
The Commissioner ruled that based on the facts provided certain amounts received by the taxpayers will not have an Australian source for the purposes of section 6-5 of the Income Tax Assessment Act 1997.
Relevant legislative provisions
Income Tax Assessment Act 1997 section 6-5