Private ruling: The undeducted purchase price (UPP) of your foreign pension.
Date of advice: 6 July 2015
Published: July 2015
Ruling period: 2013-14 financial year | 2014-15 financial year
Date scheme commenced: On or after 1 July 1983

Ruling: Q1: Are you entitled to a deductible amount in respect of the UPP of your foreign pension? Ruling Yes, your annual deductible amount and your part year deductible amount has been determined in accordance with subsection 27 H of the Income Tax Assessment Act 1936 (ITAA 1936).

Relevant facts and circumstances: This ruling is based on the facts stated below. Any material variation from these facts (including any matters not stated in the description above and any departure from these facts) will mean that the ruling will have no effect. Where there is no variation, the ruling can apply for more than just the period/s mentioned above. You are resident of Australia for income tax purposes. Your pension is paid from a retirement fund established and managed outside Australia You have provided evidence from the fund to assist the Commissioner in determining the amount of your personal contributions Your assessable income includes your pension income Your pension became payable on or after 1 July 1983 All of the pension is payable to you Your pension is payable for life 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 Assessment Act 1997 Section 960-50 - currency translation | Income Tax Regulations 1936 Regulation 9 | Income Tax Assessment Regulations 1997 Regulation 960-50.01 - currency translation ATO view documents: | Taxation Ruling IT 2498 | Taxation Ruling IT 2498A - Addendum | Other references: | Taxation Determination TD 2006/17 | Taxation Determination TD 2006/54