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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This edited version has been archived due to the length of time since original publication.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: 1012972268907

Date of advice: 22 February 2016

Ruling

Subject: Loss transfer, asset roll-over, assessability of income and the application of Part IVA.

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:

    Income Tax Assessment Act 1936 Section 177A

    Income Tax Assessment Act 1936 Section 177C

    Income Tax Assessment Act 1936 Section 177CB

    Income Tax Assessment Act 1936 Section 177D

    Income Tax Assessment Act 1936 Section 177F

    Income Tax Assessment Act 1997 Section 310-5

    Income Tax Assessment Act 1997 Section 310-10

    Income Tax Assessment Act 1997 Section 310-15

    Income Tax Assessment Act 1997 Section 310-25

    Income Tax Assessment Act 1997 Section 310-30

    Income Tax Assessment Act 1997 Section 310-45

    Income Tax Assessment Act 1997 Section 320-15

    Income Tax Assessment Act 1997 Section 320-55

    Income Tax Assessment Act 1997 Section 320-60

    Income Tax Assessment Act 1997 Section 320-137

    Income Tax Assessment Act 1997 Section 320-175

    Income Tax Assessment Act 1997 Section 320-180

    Income Tax Assessment Act 1997 Section 320-185

    Income Tax Assessment Act 1997 Section 320-195

    Income Tax Assessment Act 1997 Section 320-200

    Income Tax Assessment Act 1997 Section 320-230

    Income Tax Assessment Act 1997 Section 320-235

    Income Tax Assessment Act 1997 Section 320-240

    Income Tax Assessment Act 1997 Section 320-250

    Income Tax Assessment Act 1997 Section 320-255

    Income Tax Assessment Act 1997 Section 995-1


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