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Edited version of your written advice
Authorisation Number: 1012728226560
Ruling
Subject: Withholding tax and Part IVA
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:
• The taxpayer will not be liable to withhold and remit from certain amounts under section 12-245 or 12-250 of the Taxation Administration Act 1953);
• Based on the facts provided Part IVA of the Income Tax Assessment Act 1936 will not apply to the scheme.
Relevant legislative provisions
Taxation Administration Act 1953 section 12-245,
Taxation Administration Act 1953 section 12-250 and
Income Tax Assessment Act 1936 section 177F.