Private ruling: NFP-state/territory body
Date of advice: 5 November 2025
Published: 22 December 2025
Ruling period: Year ending DD MM 20YY | Year ending DD MM 20YY | Year ending DD MM 20YY | Year ending DD MM 20YY | Year ending DD MM 20YY | Year ending DD MM 20YY
Date scheme commenced: DD MM 20YY

Ruling: Q1: Is the Company exempt from income tax as a State/Territory Body (STB) under section 24AM of the Income Tax Assessment Act 1936 (ITAA 1936)? | A1: Yes. The Company is a STB under section 24AO of the ITAA 1936 and it is not an excluded STB as defined in section 24AT of the ITAA 1936. The income of The Company is exempt from income tax under section 24AM of the ITAA 1936.

Relevant facts and circumstances: The Company is incorporated under the Corporations Act 2001 as a proprietary company limited by shares. The Company has share capital of one share and that share is beneficially owned by a state government The Company is not an excluded STB.

Relevant legislative provisions: Income Tax Assessment Act 1936 section 24AM | Income Tax Assessment Act 1936 section 24AN | Income Tax Assessment Act 1936 section 24AO | Income Tax Assessment Act 1936 section 24AT