Private ruling: Part IVA
Published: May 2014
Ruling period: A number of income years
Date scheme commenced: During the 2014 income year

Ruling: Q1: Will the Commissioner make a determination pursuant to section 177F of the Income Tax Assessment Act 1936 (ITAA 1936) to cancel the whole or part of: (a) any tax benefit obtained under paragraph 177C(1)(b) of the ITAA 1936 in connection with the Scheme; or (b) any tax benefit obtained under paragraph 177C(1)(a) of the ITAA 1936 in connection with the Scheme? | A1: No


Relevant legislative provisions: Income Tax Assessment Act 1936 Section 177A | Income Tax Assessment Act 1936 Section 177C | Income Tax Assessment Act 1936 Section 177CB | Income Tax Assessment Act 1936 Section 177D | Income Tax Assessment Act 1936 Section 177F

Reasons for decision: Summary: Having regard to the eight matters in subsection 177D(2) of the ITAA 1936, the Commissioner does not consider that any party to the Scheme entered into the Scheme for the sole or dominant purpose of obtaining a tax benefit. Accordingly, the Commissioner will not make a determination pursuant to section 177F of the ITAA 1936 to cancel the whole or part of any tax benefit that might be obtained in connection with the Scheme.