Private ruling: Subdivision 124-M Rollover
Published: September 2014
Ruling period: year ended 30 June 20xx
Date scheme commenced: during the year ended 30 June 20xx

Ruling: Q1: Will rollover be available under Subdivision 124-M of the Income Tax Assessment Act 1997 ( ITAA 1997) in respect of the taxpayer exchanging their units in Entity 1 for units in Entity 2? | A1: Yes | Q2: Will a capital gain on the disposal of units in Entity 1 be disregarded pursuant to section 124-785? | A2: Yes | Q3: Will the cost base in Entity 2 units acquired under the arrangement be equal to the cost base of Entity 1 units exchanged under the arrangement? | A3: Yes | Q4: Will there be any ineligible proceeds as defined in section 124-790? | A4: No

Relevant facts and circumstances: The taxpayer, an original interest holder in Entity 1, applied for a private ruling in connection with a corporate group restructure under which a new Entity 2 will be interposed between the original interest holder and Entity 1.

Relevant legislative provisions: Income Tax Assessment Act 1997 Subdivision 124-M