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Edited version of private advice
Authorisation Number: 1051980488947
Date of advice: 06 May 2022
Ruling
Subject: Definition of an insurance contract
Question 1
Is the Bond written by Company X as an agent of Company Y under the agency arrangement an insurance contract as defined in section 141 of the Income Tax Assessment Act 1936?
Answer
No
Question 2
Is Company X liable to pay any income tax which has been or may be assessed in respect of the premium paid or payable under the Bond personally or as an agent of Company Y pursuant to section 144 of the ITAA 1936?
Answer
No
This ruling applies for the following period:
Income years 31 December 201X to 202X
Relevant legislative provisions
Income Tax Assessment Act 1936 section 141
Income Tax Assessment Act 1936 section 142
Income Tax Assessment Act 1936 Division 15 of Part III