Private ruling: Fixed trust
Date of advice: 20 May 2024
Published: 1 July 2024

Ruling: The Commissioner exercised the discretion in | • subsection 272-5(3) of Schedule 2F to the Income Tax Assessment Act 1936 (ITAA 1936), and | • subsection 272-30(3) of Schedule 2F to the ITAA 1936. | in relation to an ownership structure under which Company A owned 100% of the units in a unit trust with tax losses, and Company A was wholly owned (through interposed entities) by Company X (which is listed on an approved stock exchange).


Relevant legislative provisions: Income Tax Assessment Act 1936 section 272-5 of Schedule 2F | Income Tax Assessment Act 1936 section 272-30 of Schedule 2F