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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: 1051949664850

Date of advice: 2 March 2022

Ruling

Subject: Proposed restructure

The Commissioner was asked to provide administratively binding advice on the potential application of Part IVA of the Income Tax Assessment Act 1936 to a proposed restructure.

The Commissioner provided administratively binding advice on this question.