Private ruling: Internal reorganisation
Published: June 2015

Ruling: The taxpayer asked for a private ruling in respect of a proposed internal reorganisation. The Commissioner has ruled on each of the questions in the private ruling application.

Relevant facts and circumstances: Company A, an Australian resident, is a wholly owned by F Co which is a foreign resident. Company A disposes its foreign subsidiaries to F Co as part of a corporate restructure.

Relevant legislative provisions: Income Tax Assessment Act 1936 section 45B; | Income Tax Assessment Act 1936 Part IVA; | Income Tax Assessment Act 1997 Subdivision 768-G; and | Income Tax Assessment Act 1997 Division 802.