Private ruling: Capital Gains Tax Market Value Substitution and Multinational Anti-Avoidance Law (MAAL)
Date of advice: 20 December 2017
Published: May 2018

Ruling: Q1: Will section 116-30 of the Income Tax Assessment Act 1997 (“ITAA 1997”) apply to take the market value of the licences as the capital proceeds when each respective CGT Event C2 happens upon the termination of each respective licence? | A1: Yes. | Q2: Will the Commissioner apply section 177DA of the Income Tax Assessment Act 1936 (“ITAA 1936”) in relation to the termination of the licences or the contemplated supply arrangements of the entity? | A2: No.