Private ruling: Restructure and conversion
Date of advice: 28 May 2025
Published: 4 August 2025

Ruling: In order to protect the privacy of this taxpayer and the commercial in-confidence components of the transaction, the Edited Version is prepared in the following form. | The ruling relates to a transaction that the taxpayer will enter into and concerns the following provisions of the income tax legislation: | Income Tax Assessment Act 1936 subsection 6(1) | Income Tax Assessment Act 1997 Division 104 | Income Tax Assessment Act 1997 section 104-10 | Income Tax Assessment Act 1997 section 104-25 | Income Tax Assessment Act 1997 paragraph 104-25(1)(a) | Income Tax Assessment Act 1997 section 104-35 | Income Tax Assessment Act 1997 subsection 104-35(1) | Income Tax Assessment Act 1997 section 104-155 | Income Tax Assessment Act 1997 section 112-25 | Income Tax Assessment Act 1997 subsection 112-25(1) | Income Tax Assessment Act 1997 paragraph112-25(1)(b) | Income Tax Assessment Act 1997 subsection 112-25(2) | Income Tax Assessment Act 1997 subsection 112-25(3) | Corporations Act 2001 Part 5B.1 | Corporations Act 2001 subparagraph 601BC(2)(l)(i)