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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: 1051938874439

Date of advice: 12 January 2022

Ruling

Subject: Absolute entitlement

The Commissioner issued an administratively binding advice on the application of section 106-50 of the Income Tax Assessment Act 1997 in relation to whether the sole beneficiary of a trust would be absolutely entitled to the underlying trust property.