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This edited version has been archived due to the length of time since original publication.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: 1051236155253

Date of advice: 26 June 2017

Ruling

Subject: Off-market share buy-back

This ruling applies for the following periods:

1 July 2016 to 30 June 2017

Relevant facts and circumstances

Company A is an Australian tax resident.

Company A proposes to undertake an off-market share buy-back.

The buy-back price will be wholly debited to Company A’s share capital account.

Reasons for decision

The Commissioner has issued a private ruling in relation to the off-market share buy-back.