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This edited version has been archived due to the length of time since original publication.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

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Edited version of your written advice

Authorisation Number: 1012922196318

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:

Relevant legislative provisions

Income Tax Assessment Act 1997 Division 197

Income Tax Assessment Act 1997 Subsection 995-1

Income Tax Assessment Act 1997 Section 975-300

Income Tax Assessment Act 1936 Section 45A

Income Tax Assessment Act 1936 Section 45B

Income Tax Assessment Act 1936 Division 16K of Part III

Taxation Administration Act 1953 Subdivision 12-F of Part 2-5 of Schedule 1

This ruling applies for the following period:

1 July XXXX to 30 June XXXX

The scheme commences during:

2015 Income Year