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Edited version of private advice
Authorisation Number: 1052057012778
Date of advice: 12 January 2023
Ruling
Subject: Aggregated turnover
Having regard to the facts and circumstances of a company and its shareholders, the Commissioner has determined under subsection 328-125(6) of the Income Tax Assessment Act 1997 that a shareholder who owned more than 40% but less than 50% of the ordinary shares in a company did not control the company during a particular income year.