Private ruling: Deductibility of outgoings
Date of advice: 1 March 2019
Published: May 2019
Ruling period: Year ended 30 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Will Entity A be entitled to a deduction in the year ended 30 June 2017 pursuant to section 8-1 of the Income Tax Assessment Act 1997 (ITAA 1997) for the Fee? | A1: Yes, subject to the operation of section 321-60 of the ITAA 1997 as detailed in Question 2. | Q2: Will the Fee form part of the step 2 amount of the method statement in section 321-60 of the ITAA 1997 for the year ended 30 June 2017 for Entity A? | A2: Yes. | Q3: Is the Fee paid by Entity A ‘excluded expenditure’ under subsection 82KZMA(4) of the Income Tax Assessment Act 1936 ? | A3: Yes. Reasoning The Commissioner was asked a series of questions as listed above.. The Commissioner has ruled on each of the questions.


Relevant legislative provisions: Section 8-1 of Income Tax Assessment Act 1997 | Section 321-60 of the Income Tax Assessment Act 1997 | Section 82KZMA of Income Tax Assessment Act 1936 | Section 82KZL of Income Tax Assessment Act 1936 | Section 82KZMD of Income Tax Assessment Act 1936 | Section 82KZME of Income Tax Assessment Act 1936