Private ruling: Payments received
Date of advice: 2 November 2021
Published: January 2022
Ruling period: Year ended 30 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Are you liable for tax on the payments? | A1: No. In your case the other entity is treated as having constructively received the funds before they were paid to you. Consequently, the income tax consequences, if any, in relation to the payments lie with the other entity.

Relevant facts and circumstances: Another entity had the right to receive payments but agreed that amounts paid to you would be in satisfaction of their right. Amounts were paid to you in satisfaction of the other entity's right to receive payments.

Relevant legislative provisions: Income Tax Assessment Act 1997 - section 6-5 | Income Tax Assessment Act 1997 - section 6-10