Private ruling: The continuity of ownership test
Date of advice: 20 December 2018
Published: April 2019

Ruling: In order to protect the privacy of this taxpayer and the commercial in-confidence components of this particular arrangement, the Edited Version is prepared in the following form. | The ruling concerns the income tax treatment in respect of the continuity of ownership test and the ability to deduct tax losses of earlier income years and the following legislative provisions apply:


Relevant legislative provisions: Income Tax Assessment Act 1936 section 318 | Income Tax Assessment Act 1997 section 165-12 | Income Tax Assessment Act 1997 section 165-202 | Income Tax Assessment Act 1997 section 166-5 | Income Tax Assessment Act 1997 section 166-145 | Income Tax Assessment Act 1997 section 166-175 | Income Tax Assessment Act 1997 section 166-225 | Income Tax Assessment Act 1997 section 166-230 | Income Tax Assessment Act 1997 section 166-235 | Income Tax Assessment Act 1997 section 166-272 | Income Tax Assessment Act 1997 section 166-280 | Income Tax Assessment Act 1997 subsection 995-1(1) | Income Tax Assessment Regulations 1997 Regulation 995-1.05