Private ruling: Corporate Restructure - Arm's Length Dealing
Published: February 2014
Ruling period: The income year ended 30 June 20XX
Date scheme commenced: During the year ended 30 June 20XX

Ruling: Q1: Does the Commissioner agree, that in respect of each transaction entered into by the taxpayer, that it dealt with each relevant counter party at arm's length in respect of each relevant dealing? | A1: Yes. | Q2: Does the Commissioner agree that the consideration received by the taxpayer in return for the sale of certain assets to Entity B for the purposes of Division 230 of the ITAA 1997 is $X and the sale of certain other assets to Entity B for the purposes of Division 116 of the ITAA 1997 is $X being: a) equivalent to $X, being the negotiated price between the taxpayer and Entity B and b) in turn equivalent to the face value of the Promissory Notes provided as consideration by Entity B? | A2: Yes. | Q3: Does the Commissioner agree that the consideration received by the taxpayer for the purposes of Division 116 of the ITAA 1997 in return for the sale of all of the Entity C securities held by the taxpayer, is: a) equivalent to $X, being the negotiated price between the taxpayer and Entity D; and b) in turn equivalent to the face value of the Promissory Note provided as consideration by Entity D? | A3: Yes.

Relevant facts and circumstances: The taxpayer has applied for a private ruling in relation to matters concerning a corporate restructure

Relevant legislative provisions: Income Tax Assessment Act 1997 Section 103-10; | Section 104-10; | Section 108-5; | Section 110-25; | Section 116-20; | Section 116-30; | Section 116-40; | Section 230-20; | Section 230-45; | Section 230-100; | Section 230-105; | Section 230-115; | Section 230-445; and | Section 230-510.