Private ruling: Sustainable rural water use and infrastructure program
Date of advice: 28 November 2018
Published: March 2019

Ruling: The Commissioner has ruled on whether: | 1. an entity is a participant in a Sustainable Rural Water Use and Infrastructure Program agreement for the purposes of section 59-65 of the Income Tax Assessment Act 1997 (ITAA 1997) | 2. a transaction will constitute the disposal of a capital gains tax asset (CGT event A1) | 3. section 26-100 of the ITAA 1997 will be satisfied such that expenditure is not deductible | 4. section 116-30 of the ITAA 1997 will apply to treat an entity as having received market value | 5. section 112-20 of the ITAA 1997 will apply to modify the cost base of an asset to the equivalent market value, and | 6. amounts will be non-assessable non-exempt income.


Relevant legislative provisions: Section 6-23 of the Income Tax Assessment Act 1997 | Section 26-100 of the Income Tax Assessment Act 1997 | Division 59 of the Income Tax Assessment Act 1997 | Section 104-10 of the Income Tax Assessment Act 1997 | Section 112-20 of the Income Tax Assessment Act 1997 | Division 116 of the Income Tax Assessment Act 1997 | Division 118 of the Income Tax Assessment Act 1997 | Section 124-1105 of the Income Tax Assessment Act 1997