| 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: 1052368449514
Date of advice: 06 March 2025
Ruling
Subject: Capital raising
In order to protect the privacy of this taxpayer and the commercial in-confidence components of this 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:
Subsection 115-25(1) of the Income Tax Assessment Act 1997
Subsection 115-30(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
Subsection 310-10(2) of the Income Tax Assessment Act 1997
Subsection 310-10(3) of the Income Tax Assessment Act 1997
Subsection 310-10(4) of the Income Tax Assessment Act 1997
Paragraph 310-25(a) 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 310-35 of the Income Tax Assessment Act 1997
Paragraph 310-35(2)(b) of the Income Tax Assessment Act 1997
Paragraph 310-35(2)(d) of the Income Tax Assessment Act 1997
Section 310-40 of the Income Tax Assessment Act 1997
Paragraph 310-40(2)(b) of the Income Tax Assessment Act 1997
Paragraph 310-40(2)(d) 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
Subsection 310-55(2) of the Income Tax Assessment Act 1997
Subsection 310-55(3) of the Income Tax Assessment Act 1997
Subsection 310-60(4) of the Income Tax Assessment Act 1997
Subsection 310-60(5) of the Income Tax Assessment Act 1997
Subsection 310-65(2) of the Income Tax Assessment Act 1997
Subsection 310-70(1) of the Income Tax Assessment Act 1997
Subsection 310-70(2) 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
Division 310 of the Income Tax Assessment Act 1997
Subdivision 115-A 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
Section 177F of the Income Tax Assessment Act 1936
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
Subsection 177F(1) of the Income Tax Assessment Act 1936
Part IV of the Income Tax Assessment Act 1936
Section 45 of the Superannuation Industry (Supervision) Act 1993