Disclaimer This edited version has been archived due to the length of time since original publication.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: 1051282482774
Date of advice: 14 September 2017
Subject: Income tax exemption
The Commissioner advised that the trusts are STB’s (State/Territory Body) under section 24AS of the Income Tax Assessment Act 1936 (ITAA 1936) and that the trustees of the trusts are STBs under section 24AO of the ITAA 1936 and that none of the trusts and trustees are an excluded STB under section 24AT of the ITAA 1936. Therefore, the income of the trusts and of the trustees is exempt from income tax pursuant to Division 1AB of the ITAA 1936.