Private ruling: Cost base of shares after non-scrip share capital contribution
Date of advice: 23 June 2015
Published: June 2015

Ruling: Q1: Will section 110-25 of the Income Tax Assessment Act 1997 apply to the amounts to be contributed by the taxpayer company to subsidiary company, by way of non-scrip capital contributions, such that the amounts contributed, for an aggregate total of up to $x million will be included in the cost base of the ordinary shares held? | A1: Yes Facts A taxpayer company applied for a ruling in respect of section 110-25 of the Income Tax Assessment Act 1997 . The taxpayer company owns 100% of the issued capital in an offshore subsidiary company. The taxpayer company will contribute funds to the subsidiary by way of non-scrip share capital contributions, to be used by the subsidiary for an investment.