Private ruling: Public Offer Test
Date of advice: 1 July 2015
Published: July 2015

Ruling: An Australian resident company applied for a private ruling in respect of paragraph 128F(3)(d) of the Income Tax Assessment Act 1936 for a publically offered debenture issue where debentures may be issued to an investor as a result of a "reverse enquiry" made by the investor. A ruling was issued in respect of the relevant provision accepting that the issue to such investor qualified under paragraph 128F(3)(d).