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Edited version of your written advice
Authorisation Number: 1051466926228
Date of advice: 20 December 2018
Ruling
Subject: The continuity of ownership test
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 the continuity of ownership test and the ability to deduct tax losses of earlier income years and the following legislative provisions apply:
Relevant legislative provisions
Income Tax Assessment Act 1936 section 318
Income Tax Assessment Act 1997 section 165-12
Income Tax Assessment Act 1997 section 165-202
Income Tax Assessment Act 1997 section 166-5
Income Tax Assessment Act 1997 section 166-145
Income Tax Assessment Act 1997 section 166-175
Income Tax Assessment Act 1997 section 166-225
Income Tax Assessment Act 1997 section 166-230
Income Tax Assessment Act 1997 section 166-235
Income Tax Assessment Act 1997 section 166-272
Income Tax Assessment Act 1997 section 166-280
Income Tax Assessment Act 1997 subsection 995-1(1)
Income Tax Assessment Regulations 1997 Regulation 995-1.05