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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: 1052056010009

Date of advice: 29 November 2022

Ruling

Subject: Income of certain public trading trusts

Reasons for decision

The Commissioner issued a private ruling in relation to the application of Division 6C of Part III of the Income Tax Assessment Act 1936.