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This edited version has been archived due to the length of time since original publication.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: 1013023556064

Date of advice: 27 May 2016

Ruling

Subject: Effects of loss transfers, assets roll-overs and 160APHR election

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:

Subsection 160APHR(1) of the Income Tax Assessment Act 1936

Section 310-35 of the Income Tax Assessment Act 1997 (ITAA 1997)

Section 310-40 of the ITAA 1997

Section 310-55 of the ITAA 1997

Section 310-60 of the ITAA 1997

Section 310-65 of the ITAA 1997