Disclaimer This edited version has been archived due to the length of time since original publication.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: 1051453679525
Date of advice: 15 November 2018
Ruling
Subject: Application of Subdivisions 310-C and 310-E of the Income Tax Assessment Act 1997 and Part IVA of the Income Tax Assessment Act 1936
In order to protect the privacy of this taxpayer and the commercial in-confidence components of this Transaction, the Edited Version is prepared in the following form.
The ruling relates to a transaction that the taxpayer entered into and concerns the following provisions of the income tax legislation:
Subsection 310-35(1) of the Income Tax Assessment Act 1997 (ITAA 1997)
Paragraph 310-35(2)(b) of the ITAA 1997
Paragraph 310-35(2)(d) of the ITAA 1997
Subsection 310-55(2) of the ITAA 1997
Subsection 310-55(3) of the ITAA 1997
Subsection 310-65(2) of the ITAA 1997
Subsection 995-1(1) of the ITAA 1997
Subsection 177A(1) of the Income Tax Assessment Act 1936 (ITAA 1936)
Subsection 177C(1) of the ITAA 1936