Private ruling: Tainting of share capital account
Published: April 2014

Ruling: Questions at issue | In order to protect the privacy and commercial in-confidence component of this private binding ruling the following summary is provided. | The ruling concerned the following issue. | Tainting of share capital account | The Commissioner was asked questions regarding whether certain accounting entries made in the company's accounts in relation to shares issued by the company to certain employees of its overseas subsidiaries would cause the taxpayer's share capital account to become tainted under subsection 197-5(1) of the ITAA 1997. | The Commissioner has ruled that: | No. It is considered that the specific entries described in the private ruling application would not constitute a 'transfer' for the purposes of subsection 197-5(1) of the ITAA 1997.