Private ruling: Donations to a private ancillary fund
Date of advice: 7 December 2021
Published: March 2022
Ruling period: Income years ending 30 June 20XX to 30 June 20XX
Date scheme commenced: 01 July 20XX

Ruling: Q2: In relation to the proposed donation(s) from the sister fund to the fund, would the fund satisfy the rules under section 24 to Part 2 of the Taxation Administration (Private Ancillary Fund) Guidelines 2019 ? | A1: The Commissioner has ruled on each of the questions.

Relevant facts and circumstances: It is proposed that the sister fund will make donation(s) to the fund.

Relevant legislative provisions: Income Tax Assessment Act 1936 | Income Tax Assessment Act 1997


Question 1: Is the sister funda company under section 995-1 of the Income Tax Assessment Act 1997 (ITAA 1997)?