Disclaimer This edited version has been archived due to the length of time since original publication.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