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Edited version of your written advice
Authorisation Number: 1051465361505
Date of advice: 11 December 2018
Ruling
Subject: National rental affordability scheme arrangement
In view of the privacy and commercial-in-confidence issues in respect of this private ruling, the following summary is provided.
A product was established which involves participation in the National Rental Affordability Scheme (NRAS) by trustee of a Trust (the Trust).
The investors that will invest in the product through the Trust are employees of Group X that are resident in Australia (the Investors).
The Commissioner ruled that:
● The payment of certain costs in relation to the product are deductible under either section 8-1 of the Income Tax Assessment Act 1997 (ITAA 1997) or subsection 230-15(2) of the ITAA 1997.
● Group X will be entitled to refundable tax offsets pursuant to section 380-15 of the ITAA 1997, should it choose to invest in the product.