Private ruling: Division 197 - tainted share capital accounts
Date of advice: 15 August 2016
Published: September 2016
Ruling period: XX/XX/XXXX to XX/XX/XXXX
Date scheme commenced: XX/XX/XXXX

Ruling: Q1: Will any of the Proposed Accounting Entries constitute a transfer to which section 197-5 of the Income Tax Assessment Act 1997 (ITAA 1997) applies? | A1: No. | Q2: If the answer to Question 1 is yes, will the exclusion in section 197-10 of the ITAA 1997 apply to the transfer? | A2: Not applicable.

Relevant facts and circumstances: The taxpayer, applied for a ruling in relation to proposed accounting entries. Relevant facts and documents were submitted.

Relevant legislative provisions: Income Tax Assessment Act 1997 section 197-5