Private ruling: CGT rollover relief
Date of advice: 15 June 2021
Published: August 2021
Ruling period: Income tax year ended 30 June 20xx | Income tax year ended 30 June 20xx
Date scheme commenced: Income tax year beginning 01 July 20xx

Ruling: Q1: Will Company A be eligible for capital gains tax rollover relief under Subdivision 126-B of the ITAA 1997 in respect of the disposal of all the shares in Company S to Company T? | A1: Yes.

Relevant facts and circumstances: All references to legislation refer to the Income Tax Assessment Act 1997 ('ITAA 1997'), unless otherwise indicated. Company A (originator) is a member of a tax consolidated group and holder of all the shares (membership interests) in Company S. Company T (recipient) is a foreign resident and member of the same *wholly owned group as Company A. All the membership interests in Company S qualify as section 855-25 indirect Australian real property interests. Company A is eligible to apply SD 126-B roll-over relief in respect of the disposal of all the shares in Company S to Company T.