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Edited version of your written advice
Authorisation Number: 1012871014367
Date of advice: 1 September 2015
Ruling
Subject: Australian tax implications of proposed foreign restructure
In order to protect the privacy of this taxpayer and the commercial in-confidence components of
this Transaction, the Edited Version is prepared in the following form.
The ruling relates to a transaction that the taxpayer proposes to enter into and concerns the following provisions of the income tax legislation:
Income Tax Assessment Act 1997 Section 104-10,
Income Tax Assessment Act 1997 Section 110-25 and
Income Tax Assessment Act 1997 Section 112-20.