Private ruling: CGT- exempt income
Date of advice: 7 November 2023
Published: 18 December 2023

Ruling: Q1: Is the income of the Fund assessable income under subsection 6-5(3) of the Income Tax Assessment Act 1997 (ITAA 1997)? | A1: No. | Q2: Is the income of the Fund assessable income under subsection 6-10(5) of the ITAA 1997? | A2: No. | Q3: Is a net capital gain made by the Fund assessable income pursuant to section 102-5 of the ITAA 1997? | A3: No. | Q4: Are gains made by the Fund from financial arrangements assessable income under subsection 230-15(1) of the ITAA 1997? | A4: No. | Q5: Are gains from the disposal or redemption by the Fund of traditional securities assessable income under subsection 26BB(2) of the Income Tax Assessment Act 1936 (ITAA 1936)? | A5: No. | Q6: Is the income of the Fund assessable income under subsection 97(3) of the ITAA 1936? | A6: No. | Q7: Is the Fund liable to withholding tax under section 128B of the ITAA 1936 on interest, dividend or royalty income it derives from Australia? | A7: No. | Q8: Is the Fund liable to withholding tax pursuant to section 840-805 of the ITAA 1997? | A8: No.