Private ruling: Undeducted purchase price of a foreign pension or annuity
Date of advice: 27 April 2021
Published: July 2021
Ruling period: Year ended 30 June 20XX to year ended 30 June 20XX
Date scheme commenced: 9 November 20XX

Ruling: Q1: Are you entitled to an undeducted purchase price (UPP) deductible amount in respect of your foreign pension? | A1: Yes. The deductible amount has been calculated in accordance with the formula under subsection 27H(2) of the Income Tax Assessment Act 1936

Relevant facts and circumstances: You are a resident of Australia for income tax purposes. Your pension is paid by a scheme maintained overseas You have provided of the Calculation of Assessment Basis statement from the fund to assist the Commissioner in determining the amount of your personal contributions Your pension commenced on XX November 20XX and is payable for life You currently receive 100% of the pension The residual capital value of the pension is nil Your pension is paid on a monthly basis.

Relevant legislative provisions: Income Tax Assessment Act 1936 Section 27H | Income Tax Assessment Act 1936 Subsection 27H(2) | Income Tax Assessment Act 1936 Subsection 27H(4) | Income Tax Regulations 1936 Regulation 9