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Edited version of private advice
Authorisation Number: 1052364720701
Date of advice: 31 March 2025
Ruling
Subject: The application of Subdivisions 310-B, 310-D and 310-E of the Income Tax Assessment Act 1997 and Part IVA of the Income Tax Assessment Act 1936
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:
Section 104-10 of the Income Tax Assessment Act 1997
Subsection 104-10(4) of the Income Tax Assessment Act 1997
Section 108-5 of the Income Tax Assessment Act 1997
Division 310 of the Income Tax Assessment Act 1997
Section 310-1 of the Income Tax Assessment Act 1997
Section 310-5 of the Income Tax Assessment Act 1997
Section 310-10 of the Income Tax Assessment Act 1997
Subsection 310-10(1) of the Income Tax Assessment Act 1997
Paragraph 310-10(1)(a) of the Income Tax Assessment Act 1997
Subsection 310-10(2) of the Income Tax Assessment Act 1997
Subsection 310-10(3) of the Income Tax Assessment Act 1997
Paragraph 310-10(4)(a) of the Income Tax Assessment Act 1997
Subsection 310-10(5) of the Income Tax Assessment Act 1997
Section 310-25 of the Income Tax Assessment Act 1997
Section 310-30 of the Income Tax Assessment Act 1997
Subsection 310-30(1) of the Income Tax Assessment Act 1997
Section 310-45 of the Income Tax Assessment Act 1997
Subsection 310-45(1) of the Income Tax Assessment Act 1997
Paragraph 310-45(1)(a) of the Income Tax Assessment Act 1997
Paragraph 310-45(2)(a) of the Income Tax Assessment Act 1997
Subsection 310-45(3) of the Income Tax Assessment Act 1997
Paragraph 310-45(4)(a) of the Income Tax Assessment Act 1997
Section 310-50 of the Income Tax Assessment Act 1997
Subsection 310-50(1) of the Income Tax Assessment Act 1997
Subsection 310-50(2) of the Income Tax Assessment Act 1997
Subsection 310-50(3) of the Income Tax Assessment Act 1997
Section 310-55 of the Income Tax Assessment Act 1997
Subsection 310-55(1) of the Income Tax Assessment Act 1997
Paragraph 310-55(1)(a) of the Income Tax Assessment Act 1997
Paragraph 310-55(1)(b) of the Income Tax Assessment Act 1997
Section 310-60 of the Income Tax Assessment Act 1997
Subsection 310-60(1) of the Income Tax Assessment Act 1997
Subsection 310-60(3) of the Income Tax Assessment Act 1997
Section 310-65 of the Income Tax Assessment Act 1997
Subsection 310-65(1) of the Income Tax Assessment Act 1997
Section 310-70 of the Income Tax Assessment Act 1997
Subsection 310-70(1) of the Income Tax Assessment Act 1997
Subsection 310-85(1) of the Income Tax Assessment Act 1997
Subsection 310-85(2) of the Income Tax Assessment Act 1997
Subdivision 310-B of the Income Tax Assessment Act 1997
Subdivision 310-C of the Income Tax Assessment Act 1997
Subdivision 310-D of the Income Tax Assessment Act 1997
Subdivision 310-E of the Income Tax Assessment Act 1997
Subsection 995-1(1) of the Income Tax Assessment Act 1997
Subsection 177A(1) of the Income Tax Assessment Act 1936
Subsection 177C(1) of the Income Tax Assessment Act 1936
Subsection 177C(2) of the Income Tax Assessment Act 1936
Section 177F of the Income Tax Assessment Act 1936
Subsection 177F(1) of the Income Tax Assessment Act 1936