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Edited version of your written advice
Authorisation Number: 1051322192544
Date of advice: 21 December 2017
Ruling
Subject: Deductibility of expenditure, capital gains tax and the application of Part IVA
The ruling relates to an arrangement that the taxpayer entered into concerning a vertically integrated business that included mining operations, the deductibility of associated expenditure, capital gains tax, and the following provisions of the income tax legislation:
Income Tax Assessment Act 1936 Part IVA
Income Tax Assessment Act 1997 Section 8-1
Income Tax Assessment Act 1997 Section 40-25
Income Tax Assessment Act 1997 Section 40-30
Income Tax Assessment Act 1997 Section 40-40
Income Tax Assessment Act 1997 Section 40-85
Income Tax Assessment Act 1997 Section 40-185
Income Tax Assessment Act 1997 Section 40-190
Income Tax Assessment Act 1997 Section 40-285
Income Tax Assessment Act 1997 Section 40-295
Income Tax Assessment Act 1997 Section 40-300
Income Tax Assessment Act 1997 Section 40-305
Income Tax Assessment Act 1997 Section 40-735
Income Tax Assessment Act 1997 Section 40-755
Income Tax Assessment Act 1997 Section 104-10
Income Tax Assessment Act 1997 Section 108-5
Income Tax Assessment Act 1997 Section 705-47
Income Tax Assessment Act 1997 Section 705-70
Income Tax Assessment Act 1997 Division 711