| Disclaimer This edited version has been archived due to the length of time since original publication.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: 1013010043261
Date of advice: 10 May 2016
Ruling
Subject: Tier 1 capital raising
In order to protect the privacy of this taxpayer and the commercial in-confidence components of this particular arrangement, the Edited Version is prepared in the following form.
The ruling concerns a particular arrangement and the following provisions:
Income Tax Assessment Act 1936 section 6(1)
Income Tax Assessment Act 1936 subsection 24B(1)
Income Tax Assessment Act 1936 section 24D
Income Tax Assessment Act 1936 section 24J
Income Tax Assessment Act 1936 section 45
Income Tax Assessment Act 1936 section 45A
Income Tax Assessment Act 1936 section 45B
Income Tax Assessment Act 1936 section 45C
Income Tax Assessment Act 1936 section 47A
Income Tax Assessment Act 1936 Division 7A
Income Tax Assessment Act 1936 subsection 103A(1)
Income Tax Assessment Act 1936 subsection 103A(2)(a)
Income Tax Assessment Act 1936 subsection 109RB(6)
Income Tax Assessment Act 1936 subsection 109RC(2)
Income Tax Assessment Act 1936 section 159GZZZP
Income Tax Assessment Act 1936 section 177EA
Income Tax Assessment Act 1997 section 6-5
Income Tax Assessment Act 1997 section 8-1
Income Tax Assessment Act 1997 section 26-26
Income Tax Assessment Act 1997 section 104-35
Income Tax Assessment Act 1997 Division 197
Income Tax Assessment Act 1997 section 202-40
Income Tax Assessment Act 1997 section 202-45
Income Tax Assessment Act 1997 section 204-15
Income Tax Assessment Act 1997 section 204-30
Income Tax Assessment Act 1997 subsection 215-1(1)
Income Tax Assessment Act 1997 section 215-10
Income Tax Assessment Act 1997 section 215-15
Income Tax Assessment Act 1997 section 215-20
Income Tax Assessment Act 1997 section 220-30
Income Tax Assessment Act 1997 paragraph 230-40(4)(e)
Income Tax Assessment Act 1997 section 230-50
Income Tax Assessment Act 1997 subsection 230-225(1)
Income Tax Assessment Act 1997 subsection 230-255(1)
Income Tax Assessment Act 1997 subsection 230-270(1)
Income Tax Assessment Act 1997 subsection 230-330(1)
Income Tax Assessment Act 1997 subsection 230-415(1)
Income Tax Assessment Act 1997 section 245-10
Income Tax Assessment Act 1997 subsection 960-120(1)
Income Tax Assessment Act 1997 subsection 974-15(1)
Income Tax Assessment Act 1997 subsection 974-15(2)
Income Tax Assessment Act 1997 subsection 974-20(1)
Income Tax Assessment Act 1997 subsection 974-30(1)
Income Tax Assessment Act 1997 section 974-65
Income Tax Assessment Act 1997 subsection 974-70(1)
Income Tax Assessment Act 1997 subsection 974-75(1)
Income Tax Assessment Act 1997 section 974-115
Income Tax Assessment Act 1997 section 974-120
Income Tax Assessment Act 1997 subsection 974-130(1)
Income Tax Assessment Act 1997 section 974-135
Income Tax Assessment Act 1997 section 974-155
Income Tax Assessment Act 1997 subsection 974-160(1)
Income Tax Assessment Act 1997 section 975-300
Income Tax Assessment Act 1997 subsection 995-1(1)
This ruling applies for the following periods:
A number of income years
The scheme commences on:
2016 income year