Private ruling: Interest withholding tax arising from the acquisition of Bonds
Date of advice: 29 September 2016
Published: November 2016
Ruling period: Income year ended 30 June 20xx to income year ended 30 June 20xx
Date scheme commenced: Income year ended 30 June 20xx

Ruling: Q1: Will Article 1 of the Convention between Australia and the Relevant Country for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income [2008] ATS 21 (the Relevant Convention) apply to Company A? | A1: Yes. | Q2: Will Article 11(3)(b) of the Relevant Convention apply to the interest arising from the Bonds issued by Company B and derived by Company A such that the interest will not be liable to tax in Australia? | A2: Yes. | Q3: Will interest income arising from Bonds issued by Company B and derived by Company A be subject to income tax in accordance with subsection 128B(5) of Income Tax Assessment Act 1936 ? | A3: No.




Subject: Interest withholding tax arising from the acquisition of Bonds: Company A derived interest through Bonds issued by Company B.