Private ruling: Infrastructure Securitisation Transaction
Date of advice: 13 April 2016
Published: June 2016

Ruling: Q1: Are the payments received by the Project Entity from the Government in respect of construction of the Infrastructure Project assessable under section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997)? | A1: Yes. | Q2: Are the costs incurred by the Project Entity in respect of the construction of the Infrastructure Project deductible under section 8-1 of the ITAA 1997? | A2: Yes. | Q3: Does Division 250 of the ITAA 1997 apply to the Project Entity in relation to the assets that will form part of the Infrastructure Project? | A3: No.


Relevant legislative provisions: Income Tax Assessment Act 1997 section 6-5 | Income Tax Assessment Act 1997 section 8-1 | Income Tax Assessment Act 1997 Division 250