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Edited version of your written advice
Authorisation Number: 1051487513676
Date of advice: 1 March 2019
Ruling
Subject: Deductibility of outgoings
Question 1
Will Entity A be entitled to a deduction in the year ended 30 June 2017 pursuant to section 8-1 of the Income Tax Assessment Act 1997 (ITAA 1997) for the Fee?
Answer
Yes, subject to the operation of section 321-60 of the ITAA 1997 as detailed in Question 2.
Question 2
Will the Fee form part of the step 2 amount of the method statement in section 321-60 of the ITAA 1997 for the year ended 30 June 2017 for Entity A?
Answer
Yes.
Question 3
Is the Fee paid by Entity A ‘excluded expenditure’ under subsection 82KZMA(4) of the Income Tax Assessment Act 1936?
Answer
Yes.
Reasoning
The Commissioner was asked a series of questions as listed above..
The Commissioner has ruled on each of the questions.
This ruling applies for the following period:
Year ended 30 June 20XX
1 July 20XX
Relevant legislative provisions
Section 8-1 of Income Tax Assessment Act 1997
Section 321-60 of the Income Tax Assessment Act 1997
Section 82KZMA of Income Tax Assessment Act 1936
Section 82KZL of Income Tax Assessment Act 1936
Section 82KZMD of Income Tax Assessment Act 1936
Section 82KZME of Income Tax Assessment Act 1936