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Edited version of your written advice
Authorisation Number: 1013036469723
Date of advice: 17 June 2016
Ruling
Subject: Division 310 and Part IVA
In view of privacy and commercial in-confidence issues in respect of this private ruling, the following summary is provided.
The Commissioner has ruled that Part IVA of the Income Tax Assessment Act 1936 will not apply to a scheme involving a straightforward application of Division 310 of the Income Tax Assessment Act 1997.
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 177F
Income Tax Assessment Act 1997 Section 310-10
Income Tax Assessment Act 1997 Section 310-85