Private ruling: Capital raising
Date of advice: 23 June 2025
Published: 18 August 2025

Ruling: In order to protect the privacy of this taxpayer and the commercial in-confidence components of this scheme, the Edited Version is prepared in the following form. | The ruling relates to a scheme that the taxpayer entered into and concerns the following provisions of the income tax legislation: | Section 26BC of the Income Tax Assessment Act 1936 | Part IVA of the Income Tax Assessment Act 1936 | Subsection 177A(5) of the Income Tax Assessment Act 1936 | Subsection 177D(1) of the Income Tax Assessment Act 1936 | Subsection 177D(2) of the Income Tax Assessment Act 1936 | Section 177F of the Income Tax Assessment Act 1936 | Paragraph 177F(1)(a) of the Income Tax Assessment Act 1936 | Paragraph 177F(1)(c) of the Income Tax Assessment Act 1936 | Section 100-45 of the Income Tax Assessment Act 1997 | Section 102-5 of the Income Tax Assessment Act 1997 | Section 102-10 of the Income Tax Assessment Act 1997 | Section 102-15 of the Income Tax Assessment Act 1997 | Section 108-5 of the Income Tax Assessment Act 1997 | Section 121-20 of the Income Tax Assessment Act 1997 | Subsection 121-20(1) of the Income Tax Assessment Act 1997 | Subsection 121-20(2) of the Income Tax Assessment Act 1997 | Subsection 121-20(3) of the Income Tax Assessment Act 1997 | Subsection 121-20(4) of the Income Tax Assessment Act 1997 | Subsection 121-20(5) of the Income Tax Assessment Act 1997 | Section 121-25 of the Income Tax Assessment Act 1997 | Section 216-30 of the Income Tax Assessment Act 1997 | Section 295-385 of the Income Tax Assessment Act 1997