Private ruling: Source of Income
Published: November 2014

Ruling: What this ruling is about: | In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided. | The taxpayer proposes to enter into a debt factoring arrangement. | The Commissioner ruled that based on the facts provided certain amounts received by the taxpayers will not have an Australian source for the purposes of section 6-5 of the Income Tax Assessment Act 1997 .


Relevant legislative provisions: Income Tax Assessment Act 1997 section 6-5