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Edited version of your written advice
Authorisation Number: 1051389895959
Date of advice: 3 July 2018
Ruling
Subject: Income tax treatment in respect of an arrangement involving an offshore banking unit
In order to protect the privacy of this taxpayer and the commercial in-confidence components of this particular arrangement, the Edited Version is prepared in the following form.
The ruling concerns the income tax treatment in respect of an arrangement involving an Offshore Banking Unit and whether certain activities constitute Offshore Banking activity and the following legislative provisions apply:
Relevant legislative provisions
Income Tax Assessment Act 1936 section 121C
Income Tax Assessment Act 1936 section 121D
Income Tax Assessment Act 1936 section 121EAA
Income Tax Assessment Act 1936 section 121ED
Income Tax Assessment Act 1936 section 121EDA
Income Tax Assessment Act 1997 subsection 701-1(1)
Income Tax Assessment Act 1997 subsection 719-2(1)
Income Tax Assessment Act 1936 section 121DB