Private ruling: Division 855 of the Income Tax Assessment Act 1997 (ITAA 1997) and wind farm assets
Date of advice: 7 August 2018
Published: October 2018

Ruling: Q1: For the purposes of applying the principal asset test in section 855-30 of the ITAA 1997 to the membership interest held by ForCo in AusCo, are the Wind Turbine Generators (WTGs) held by AusCo’s wholly-owned subsidiary AusSubCo taxable Australian real property under section 855-20 of the ITAA 1997? | A1: No.




Subject: Division 855 of the Income Tax Assessment Act 1997 (ITAA 1997) and wind farm assets: In order to protect the privacy and commercial in-confidence components of this private binding ruling the following summary is provided: | The Commissioner has ruled on the specific question.