Private ruling: Partnership arrangement
Published: July 2012

Ruling: Q1: If the partner interest is held through an Australian resident corporate entity, will the share of the net income of the partnership, which the Australian resident corporate entity is entitled to, be assessable income pursuant to section 92 of the ITAA 1936? | A1: Yes | Q2: Will income received from Partnership P be assessable income of Mr X? | A2: Yes | Q3: Will the Payments made by Partnership M to Partnership P be deductible under section 8-1 of the ITAA 1997? | A3: Yes | Q4: Will the Payments received by Partnership M from Partnership P be assessable income to Partnership M when derived pursuant to section 6-5 of the ITAA 1997? | A4: Yes | Q5: Will Mr X, as a partner in Partnership M, make a capital gain or a capital loss under section 104-10 (CGT event A1) of the Income Tax Assessment Act 1997 at the time of admission of a corporate partner? | A5: Yes. | Q6: Following the "admission" of the corporate partner in Partnership M, will Mr X, a partner in Partnership M, make a capital gain or a capital loss under Section 104-10 (CGT event A1) of the ITAA 1997 for the ongoing admission and retirement of partners to or from Partnership M? | A6: No




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