Private ruling: Sovereign Immunity
Published: April 2014

Ruling: A1: No.




Question at issue: In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided. | Will the Australian Taxation Office (ATO) impose liability to income tax (including capital gains tax) or withholding tax on a foreign government entity and its wholly owned offshore subsidiary on income derived from its investment into Australian entities that hold assets?