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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: 1051706835735

Date of advice: 26 June 2020

Date of advice: 26 June 2020

Ruling

Subject: Crossed border reorganisation

The Commissioner issued a Private Binding Ruling in relation to a proposed crossed border reorganisation issue. The Commissioner considered a number of income tax provisions including those contained in Subdivision 768-G of the Income Tax Assessment Act 1997, and those contained section 128B(1) and Part IVA of the Income Tax Assessment Act 1936.