Private ruling: Payment received
Date of advice: 12 August 2022
Published: November 2022
Ruling period: Year ended 30 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Are you liable for tax on any part of the lump sum payment? | A1: No. In your case the other entity is treated as having constructively received the funds before they were paid to you and therefore is treated as having received the payment for tax purposes.

Relevant facts and circumstances: Another entity had the right to receive a lump sum payment, but that amount was paid to you in satisfaction of that right.

Relevant legislative provisions: Income Tax Assessment Act 1997 section 6-5 | Income Tax Assessment Act 1997 section 6-10