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Edited version of private advice
Authorisation Number: 1052311639515
Date of advice: 9 October 2024
Ruling
Subject: Withholding tax implications
The Commissioner was asked a series of questions in relation to the application of Division 830 of the Income Tax Assessment Act 1997 (ITAA 1997), section 94D of the Income Tax Assessment Act 1936 (ITAA 1936) and certain withholding tax implications under Division 11A of the ITAA 1936 and Subdivision 840-M of the ITAA 1997.
The Commissioner has ruled on each of these questions.