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This edited version has been archived due to the length of time since original publication.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 written advice

Authorisation Number: 1012785791122

Ruling

Subject: CGT cost base & deemed dividend

In order to protect the privacy of this taxpayer and the commercial in-confidence components of this arrangement, the Edited Version of this private ruling is prepared in the following form.

This ruling concerns the CGT cost base & deemed dividend matters in respect of this particular taxpayer's present arrangement.

This ruling applies for the following periods:

A number of income years

The scheme commences on:

During the 2015 income year

Relevant legislative provisions

ITAA 1936

    • Income Tax Assessment Act 1936 Division 16K

    • Income Tax Assessment Act 1936 Subsection 6(1)

    • Income Tax Assessment Act 1936 Section 44

    • Income Tax Assessment Act 1936 Section 45B

ITAA 1997

    • Income Tax Assessment Act 1997 Section 20-25

    • Income Tax Assessment Act 1997 Section 102-20

    • Income Tax Assessment Act 1997 Section 110-25

    • Income Tax Assessment Act 1997 Section 110-55


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