Disclaimer
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: 1052046090862

Date of advice: 17 October 2022

Ruling

Subject: Disposal of assets

In order to protect the privacy of this taxpayer and the commercial in-confidence components of this scheme, the Edited Version is prepared in the following form.

The ruling relates to a scheme that the taxpayer entered into and concerns the following provisions of the income tax legislation:

Income Tax Assessment Act 1936 Part IVA

Income Tax Assessment Act 1936 subsection 177A(1)

Income Tax Assessment Act 1936 subsection 177C(1)

Income Tax Assessment Act 1936 section 177D

Income Tax Assessment Act 1936 subsection 177F(1)

Income Tax Assessment Act 1936 section 262A

Income Tax Assessment Act 1997 section 100-45

Income Tax Assessment Act 1997 section 102-5

Income Tax Assessment Act 1997 section 102-10

Income Tax Assessment Act 1997 section 102-15

Income Tax Assessment Act 1997 subsection 121-20(1)

Income Tax Assessment Act 1997 subsection 121-20(2)

Income Tax Assessment Act 1997 paragraph 121-20(3)(a)

Income Tax Assessment Act 1997 paragraph 121-20(3)(b)

Income Tax Assessment Act 1997 section 121-25

Income Tax Assessment Act 1997 Division 295

Income Tax Assessment Act 1997 subsection 995-1(1)

Superannuation Industry (Supervision) Act 1993 section 69A