Private ruling: Sovereign Immunity
Published: December 2013
Ruling period: For the period 1 July 2014 to 30 June 2015 | For the period 1 July 2015 to 30 June 2016 | For the period 1 July 2016 to 30 June 2017
Date scheme commenced: 1 January 2009

Ruling: Q1: Are the entity and its wholly-owned offshore subsidiary exempt from Australian income tax (including capital gains tax) and withholding tax on their interest income, dividend income, trust distributions and any other income (including any managed investment trust distributions) derived from their minority investment in the special purpose vehicles used to acquire Australian assets under the principle of sovereign immunity? | A1: Yes

Relevant facts and circumstances: The description of the scheme to which this ruling applies incorporates the scheme and assumption as set out in the previous ruling, and information provided in the application for private ruling and further correspondence. There is only one non-material change to the description of scheme as set out in the previous ruling.


Reasons for decision: Summary: As the only change to the scheme as set out in the previous ruling is not material the reasons for decision as outlined in the previous ruling continue to apply. Therefore, the entity and its wholly-owned offshore subsidiary will be exempt from Australian income tax (including capital gains tax) and withholding tax on their interest income, dividend income, trust distributions and any other income (including any managed investment trust distributions) derived from their minority investment in the special purpose vehicles used to acquire Australian assets under the principle of sovereign immunity.