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This edited version has been archived due to the length of time since original publication.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: 1012926442204

Date of advice: 18 December 2015

Ruling

Subject: The Financing Arrangement

A taxpayer applied for a private binding ruling about a financing arrangement and asked for a ruling on how the following legislative provisions would apply to the financing arrangement:

Subsection 128A(1AB) of the Income Tax Assessment Act 1936

Section 177F of the Income Tax Assessment Act 1936

Section 26-25 of the Income Tax Assessment Act 1997

Section 230-15 of the Income Tax Assessment Act 1997

Section 230-45 of the Income Tax Assessment Act 1997

Section 974-15 of the Income Tax Assessment Act 1997

Section 974-80 of the Income Tax Assessment Act 1997

The Commissioner issued a ruling on the questions asked by the taxpayer.