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Edited version of your written advice
Authorisation Number: 1012986248824
Date of advice: 31 March 2016
Ruling
Subject: An Australian resident company - Payments to an Australian resident trust
Question 1
Is the Australian resident company entitled to claim a deduction payments to the Australian resident trust, under section 8-1 of the Income Tax Assessment Act 1997 ('ITAA 1997')?
Advice/Answers
Yes.
Question 2
Is the Australian resident company entitled to claim a deduction for the payments made to the Australian resident trust, under section 230-15 of the ITAA 1997?
Advice/Answers
No.
Question 3
Is the Australian resident company required to include in its assessable income under section 6-5 of the ITAA 1997, amounts derived from its foreign related entities in respect of payments to the Australian resident trust?
Advice/Answers
Yes.