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Edited version of your written advice
Authorisation Number: 1013109493693
Date of advice: 3 November 2016
Ruling
Subject: Tax consequences of leasing certain assets to non-residents
In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided.
The taxpayer, who is a resident for Australian income tax purposes, sought a ruling on whether certain transactions would constitute an offshore banking (OB) activity.
The Commissioner ruled:
● Certain transactions are an 'OB activity' of the taxpayer within the meaning of subsection 121D(1) of the Income Tax Assessment Act 1936.