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Edited version of your written advice
Authorisation Number: 1012928468759
Date of advice: 21 December 2015
Ruling
Subject: Sovereign immunity
Question
Will the foreign government entity be exempt from income and withholding taxes on:
• interest
• income and gains from its investments
• gains on the disposal of its investments
under the common law doctrine of sovereign immunity?
Answer
Yes.
This ruling applies for the following periods:
Years ended 30 June XXXX to XXXX
The scheme commences:
During the year ended 30 June XXXX.
Relevant facts and circumstances
The foreign government entity invests government funds.
Relevant legislative provisions
Income Tax Assessment Act 1936 section 128B
Income Tax Assessment Act 1997 section 4-1
Reasons for decision
The foreign government entity satisfies the conditions for exemption from income and withholding taxes under the doctrine of sovereign immunity in respect of interest, income and gains from its investments.