Private ruling: Dividend access share scheme arrangement
Date of advice: 3 December 2024
Published: 20 January 2025
Ruling period: 1 July 20XX to 30 June 20XX
Date scheme commenced: DD MM 20XX

Ruling: Q1: Is the arrangement a scheme to which section 177F of the Income Tax Assessment Act 1936 (ITAA 1936) applies? | A1: No. | Q2: Is the arrangement a scheme to which section 177E of the ITAA 1936 applies? | A2: No. | Q3: Is the arrangement a scheme to which section 177EA of the ITAA 1936 applies? | A3: No. | Q4: Will the arrangement give rise to a taxing event generating a gain under Division 725 of the Income Tax Assessment Act 1997 (ITAA 1997)? | A4: No.

Relevant facts and circumstances: The Commissioner has been provided with facts outlining the scheme involving dividend access share arrangement.

Relevant legislative provisions: Income Tax Assessment Act 1936 section 177A | Income Tax Assessment Act 1936 section177C | Income Tax Assessment Act 1936 section177CB | Income Tax Assessment Act 1936 section177D | Income Tax Assessment Act 1936 section177EA | Income Tax Assessment Act 1936 section177F | Income Tax Assessment Act 1997 Division725 | Income Tax Assessment Act 1997 section725 - 50 | Income Tax Assessment Act 1997 section725 - 90 | Income Tax Assessment Act 1997 section725-145 | Income Tax Assessment Act 1997 section725 - 150 | Income Tax Assessment Act 1997 section725 - 245 | Income Tax Assessment Act 1997 section725 - 365 | Income Tax Assessment Act 1997 section104 - 250 | Income Tax Assessment Act 1997 section727 - 520 | Income Tax Assessment Act 1997 section104 - 250 | Income Tax Assessment Act 1997 section995-1

Reasons for decision: Summary: The Commissioner has ruled favourably for the taxpayer regarding the questions asked in relation to the dividend access share scheme arrangement.