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Edited version of private advice
Authorisation Number: 1052021081627
Date of advice: 12 August 2022
Ruling
Subject: Payment received
Question
Are you liable for tax on any part of the lump sum payment?
Answer
No.
In your case the other entity is treated as having constructively received the funds before they were paid to you and therefore is treated as having received the payment for tax purposes.
This ruling applies for the following period:
Year ended 30 June 20XX
The scheme commences on:
1 July 20XX
Relevant facts and circumstances
Another entity had the right to receive a lump sum payment, but that amount was paid to you in satisfaction of that right.
Relevant legislative provisions
Income Tax Assessment Act 1997 section 6-5
Income Tax Assessment Act 1997 section 6-10