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Edited version of private advice
Authorisation Number: 1051785089759
Date of advice: 22 January 2021
Ruling
Subject: Pre-capital gains tax status of goodwill
The Commissioner made a private ruling confirming that the majority underlying interests in the CGT assets of a company as at the relevant test days were held by the ultimate owners who also had majority underlying interests in those CGT assets at the end of the starting day pursuant to subsection 149-60(1) of the Income Tax Assessment Act 1997.