Private ruling: Proposed Implementation Steps
Published: December 2013
Ruling period: 1 July 2013 to 30 June 2014
Date scheme commenced: 1 July 2013

Ruling: Q1: Will CGT event E1 (section 104-55 of the Income Tax Assessment Act 1997 (ITAA 1997)) happen for the Taxpayer? | A1: No | Q2: Will CGT event A1 (section 104-10 of the ITAA 1997) happen for the Taxpayer? | A2: No | Q3: Will Division 6C of Part III of the Income Tax Assessment Act 1936 ( ITAA 1936) apply? | A3: No | Q4: Will the Commissioner exercise the discretion under subsection 272-5(3) of Schedule 2F to the ITAA 1936? | A4: Yes

Relevant facts and circumstances: HeadCo is planning on entering into a transaction. As part of the transaction, a number of steps need to be implemented. One of these steps is to obtain the approval of the shareholders in the various Sub-Cos to vary their respective Constitutions.

Relevant legislative provisions: Income Tax Assessment Act 1997 Section 104-10 | Income Tax Assessment Act 1997 Section 104-55 | Income Tax Assessment Act 1936 Division 6C | Income Tax Assessment Act 1936 Schedule 2F