Private ruling: Sovereign Immunity
Date of advice: 30 November 2015
Published: January 2016

Ruling: Q1: Will Entity B be immune from income and withholding taxes on: • interest received on loans advanced to Entity C; • distributions received from Entity B's interest in Entities C, D, E and F; and • any gains made by Entity B on the disposal of these interests, under the common law doctrine of sovereign immunity? | A1: Yes.




Date of advice: 30 November 2015: In order to protect the privacy and commercial in-confidence components of the private binding ruling the following Question and Answer is provided.