Disclaimer This edited version has been archived due to the length of time since original publication.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 private advice
Authorisation Number: 1051604943896
Date of advice: 11 November 2019
Ruling
Subject: Capital raising
The Edited Version has been prepared in the following form in order to protect the privacy of this taxpayer and the commercial in-confidence components of this particular arrangement.
The Commissioner issued a ruling on a proposed capital raising transaction covering the following provisions:
· paragraph 177EA(5)(a) of the Income Tax Assessment Act 1936
· section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997)
· section 26-26 of the ITAA 1997
· section 197-5 of the ITAA 1997, and
· subsection 995-1(1) of the ITAA 1997.