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Edited version of private advice
Authorisation Number: 1052184611996
Date of advice: 10 November 2023
Ruling
Subject: The application of sections 102-5, 102-10 and 121-20 of the Income Tax Assessment Act 1997 and Part IVA of the Income Tax Assessment Act 1936 to the 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:
Section 100-45 of the Income Tax Assessment Act 1997
Section 102-5 of the Income Tax Assessment Act 1997
Section 102-10 of the Income Tax Assessment Act 1997
Section 102-15 of the Income Tax Assessment Act 1997
Section 108-5 of the Income Tax Assessment Act 1997
Section 121-20 of the Income Tax Assessment Act 1997
Subsection 121-20(1) of the Income Tax Assessment Act 1997
Subsection 121-20(2) of the Income Tax Assessment Act 1997
Subsection 121-20(3) of the Income Tax Assessment Act 1997
Subsection 121-20(4) of the Income Tax Assessment Act 1997
Subsection 121-20(5) of the Income Tax Assessment Act 1997
Section 121-25 of the Income Tax Assessment Act 1997
Section 295-385 of the Income Tax Assessment Act 1997
Part IVA of the Income Tax Assessment Act 1936
Subsection 177A(5) of the Income Tax Assessment Act 1936
Subsection 177D(1) of the Income Tax Assessment Act 1936
Subsection 177D(2) of the Income Tax Assessment Act 1936
Section 177F of the Income Tax Assessment Act 1936
Section 69A of the Superannuation Industry (Supervision) Act 1993