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Edited version of your written advice
Authorisation Number: 1012865765637
Date of advice: 16 September 2015
Ruling
Subject: International restructure
Company A is a company incorporated in Australia. It wants to rationalise its group structure so
that it can hold shares in certain overseas subsidiaries directly.
The Commissioner issued a Private Ruling on sections 126-50, 104-135, 768-5 and 768-505, and
subsection 995-1(1), of the ITAA 1997.
This ruling applies for the following periods:
1 July 2015 to 30 June 2016
Relevant legislative provisions
Income Tax Assessment Act 1997 section 126-50
Income Tax Assessment Act 1997 section 104-135
Income Tax Assessment Act 1997 section 768-5
Income Tax Assessment Act 1997 section 768-505
Income Tax Assessment Act 1997 subsection 995-1(1)