Private ruling: Sovereign Immunity
Date of advice: 9 March 2016
Published: April 2016

Ruling: Q1: Will Entity B be immune from income and withholding taxes on: • interest received on a loan advanced to Entity C • distributions received from Entity B's interest in Entities C, D, E and F; and • any gains made by Entity B on the disposal of these interests under the common law doctrine of sovereign immunity? | A1: Yes.




Subject: Sovereign Immunity: In order to protect the privacy and commercial in-confidence components of the private binding ruling the following Question and Answer is provided.