Disclaimer
This edited version has been archived due to the length of time since original publication.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: 1012915869957

Date of advice: 15 December 2015

Ruling

Subject: Issue of Mandatory Redeemable Preference Shares

The Commissioner issued a ruling on the application of the following provisions to a proposed issue of Mandatory Redeemable Preference Shares:

Income Tax Assessment Act 1936 section 45A

Income Tax Assessment Act 1936 section 45B

Income Tax Assessment Act 1936 section 45C

Income Tax Assessment Act 1997 section 165-150

Income Tax Assessment Act 1997 section 165-155

Income Tax Assessment Act 1997 section 165-160

Income Tax Assessment Act 1997 section 165-10

Income Tax Assessment Act 1997 section 165-12

Income Tax Assessment Act 1997 section 166-5

Income Tax Assessment Act 1997 section 166-145

Income Tax Assessment Act 1997 section 166-175

Income Tax Assessment Act 1997 section 166-225

Income Tax Assessment Act 1997 section 230-15

Income Tax Assessment Act 1997 section 230-45

Income Tax Assessment Act 1997 section 245-10

Income Tax Assessment Act 1997 section 245-15

Income Tax Assessment Act 1997 section 245-37

Income Tax Assessment Act 1997 section 701-1

Income Tax Assessment Act 1997 section 703-30

Income Tax Assessment Act 1997 Subdivision 709-A

Income Tax Assessment Act 1997 section 719-250

Income Tax Assessment Act 1997 section 719-255

Income Tax Assessment Act 1997 section 719-260

Income Tax Assessment Act 1997 section 960-130

Income Tax Assessment Act 1997 section 960-135

Income Tax Assessment Act 1997 section 974-15

Income Tax Assessment Act 1997 section 974-20

Income Tax Assessment Act 1997 section 974-80

Income Tax Assessment Act 1997 section 974-130

Income Tax Assessment Act 1997 section 974-135

Income Tax Assessment Act 1997 section 974-155

Income Tax Assessment Act 1997 section 974-160

Income Tax Assessment Act 1997 section 975-300

Corporations Act 2001 section 254K

This ruling applies for the following period:

1 July XXXX to 30 June XXXX

The scheme commences during:

2015 income year