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This edited version has been archived due to the length of time since original publication.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.

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Edited version of your written advice

Authorisation Number: 1051477705511

Date of advice: 25 January 2019

Ruling

Subject: Income tax consequences on the receipt of ordinary shares in a company under the arrangement

The Commissioner provided advice on section 6-5, section 6-10 and section 110-25 of the Income Tax Assessment Act 1997 in relation to the arrangement.