| Disclaimer This edited version has been archived due to the length of time since original publication.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: 1012972251371
Date of advice: 17 February 2016
Ruling
Subject: Loss transfer, asset roll-over and assessability of income
In order to protect the privacy of this taxpayer and the commercial in-confidence components of this Transaction, the Edited Version is prepared in the following form.
The ruling relates to a transaction that the taxpayer entered into and concerns the following provisions of the income tax legislation:
Section 26AH of the Income Tax Assessment Act 1936
Section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997)
Section 118-300 of the ITAA 1997
Section 118-350 of the ITAA 1997
Section 295-85 of the ITAA 1997
Section 310-10 of the ITAA 1997
Paragraph 310-25(a) of the ITAA 1997
Subsection 310-30(1) of the ITAA 1997
Section 310-45 of the ITAA 1997
Section 995-1 of the ITAA 1997