Private ruling: Sovereign immunity
Date of advice: 9 April 2020
Published: May 2020
Ruling period: xx MMMM 20xx to xx MMMM 20xx
Date scheme commenced: xx MMMM 20xx

Ruling: Q1: Will Foreign Co be immune from income tax and withholding tax on income derived from its investment in the Test Entities under the common law doctrine of sovereign immunity for the period xx MMMM 20xx to 30 June 20XX? | A1: Yes. | Q2: Is the ordinary and statutory income derived by Foreign Co from the Test Entities not assessable and not exempt income under section 880-105 of the ITAA 1997 for the period 1 July 20XX to xx MMMM 20xx? | A2: Yes. | Q3: Is any loss incurred by Foreign Co in respect of interests in the Test Entities not deductible under section 880-110 of the ITAA 1997 for the period 1 July 20XX to xx MMMM 20xx? | A3: Yes. | Q4: Is any capital gain or capital loss made by Foreign Co with respect to its investments in the Test Entities disregarded under sections 880-115 and 880-120 of the ITAA 1997 respectively for the period 1 July 20XX to xx MMMM 20xx? | A4: Yes.