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: 1052369766736

Date of advice: 6 March 2025

Ruling

Subject:Application of Subdivisions 310-B and 310-D 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 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:

Income Tax Assessment Act 1936 subsection 177A(1)

Income Tax Assessment Act 1936 subsection 177C(1)

Income Tax Assessment Act 1936 subsection 177C(2)

Income Tax Assessment Act 1936 section 177F

Income Tax Assessment Act 1936 subsection 177F(1)

Income Tax Assessment Act 1936 part IV

Income Tax Assessment Act 1997 section 108-5

Income Tax Assessment Act 1997 Division 310

Income Tax Assessment Act 1997 section 310-1

Income Tax Assessment Act 1997 section 310-5

Income Tax Assessment Act 1997 section 310-10

Income Tax Assessment Act 1997 subsection 310-10(1)

Income Tax Assessment Act 1997 subsection 310-10(2)

Income Tax Assessment Act 1997 subsection 310-10(3)

Income Tax Assessment Act 1997 paragraph 310-10(3)(a)

Income Tax Assessment Act 1997 paragraph 310-10(4)(a)

Income Tax Assessment Act 1997 subsection 310-10(5)

Income Tax Assessment Act 1997 paragraph 310-25(a)

Income Tax Assessment Act 1997 section 310-30

Income Tax Assessment Act 1997 subsection 310-30(1)

Income Tax Assessment Act 1997 section 310-45

Income Tax Assessment Act 1997 subsection 310-45(1)

Income Tax Assessment Act 1997 paragraph 310-45(1)(a)

Income Tax Assessment Act 1997 paragraph 310-45(2)(a)

Income Tax Assessment Act 1997 paragraph 310-45(2)(c)

Income Tax Assessment Act 1997 subsection 310-45(3)

Income Tax Assessment Act 1997 subsection 310-45(3)

Income Tax Assessment Act 1997 paragraph 310-45(4)(a)

Income Tax Assessment Act 1997 section 310-50

Income Tax Assessment Act 1997 subsection 310-55(1)

Income Tax Assessment Act 1997 paragraph 310-55(1)(a)

Income Tax Assessment Act 1997 paragraph 310-55(1)(b)

Income Tax Assessment Act 1997 section 310-60

Income Tax Assessment Act 1997 subsection 310-60(1)

Income Tax Assessment Act 1997 subsection 310-60(3)

Income Tax Assessment Act 1997 paragraph 310-60(3)(a)

Income Tax Assessment Act 1997 paragraph 310-60(3)(b)

Income Tax Assessment Act 1997 subsection 310-65(1)

Income Tax Assessment Act 1997 subsection 310-70(1)

Income Tax Assessment Act 1997 subsection 310-85(1)

Income Tax Assessment Act 1997 subsection 310-85(2)

Income Tax Assessment Act 1997 subdivision 310-B

Income Tax Assessment Act 1997 subdivision 310-D

Income Tax Assessment Act 1997 subdivision 310-E

Income Tax Assessment Act 1997 subsection 995-1(1)

Superannuation Industry (Supervision) Act 1993 section 45