| 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: 1052363030399
Date of advice: 28 May 2025
Ruling
Subject: Restructure and conversion
In order to protect the privacy of this taxpayer and the commercial in-confidence components of the transaction, the Edited Version is prepared in the following form.
The ruling relates to a transaction that the taxpayer will enter into and concerns the following provisions of the income tax legislation:
Income Tax Assessment Act 1936 subsection 6(1)
Income Tax Assessment Act 1936 paragraph 6(1)(b)
Income Tax Assessment Act 1997 section 4-1
Income Tax Assessment Act 1997 Division 104
Income Tax Assessment Act 1997 section 104-10
Income Tax Assessment Act 1997 section 104-25
Income Tax Assessment Act 1997 section 104-35
Income Tax Assessment Act 1997 section 104-155
Income Tax Assessment Act 1997 paragraph 104-155(1)(a)
Income Tax Assessment Act 1997 subsection 703-15(2)
Income Tax Assessment Act 1997 subsection 960-60(1)
Income Tax Assessment Act 1997 section 960-65
Income Tax Assessment Act 1997 section 960-70
Income Tax Assessment Act 1997 subsection 960-70(4)
Income Tax Assessment Act 1997 section 960-100
Income Tax Assessment Act 1997 subsection 995-1(1)
Corporations Act 2001 section 292
Corporations Act 2001 Part 5B.1
Corporations Act 2001 section 601BM