Private ruling: Income tax treatment of return of capital
Date of advice: 15 June 2016
Published: July 2016

Ruling: Q1: Will any part of the return of capital be a dividend as defined in subsection 6(1) and the exclusion under subsection 6(4) of the Income Tax Assessment Act 1936 (ITAA 1936)? | A1: No. | Q2: Will the Commissioner make a determination under subsection 45A(2) of the ITAA 1936 that section 45C of the ITAA 1936 applies in relation to the whole or part of the capital amount? | A2: No. | Q3: Will the Commissioner make a determination under subsection 45B(3) of the ITAA 1936 that section 45C of the ITAA 1936 applies in relation to the whole or part of the capital amount? | A3: No.




Subject: Income tax treatment of return of capital: In order to protect the privacy and commercial-in-confidence components of this private ruling the following summary is provided.