Private ruling: Part IVA
Published: April 2014

Ruling: Q1: Will the Commissioner confirm that no determination will be made pursuant to section 177F of the Income Tax Assessment Act 1936 (ITAA 1936) to cancel the whole or part of any tax benefit that might be obtained in connection with the Scheme under a postulate? | A1: Yes.


Relevant legislative provisions: Income Tax Assessment Act 1936 Section 177D | Income Tax Assessment Act 1936 Section 177F

Reasons for decision: Summary: Having regard to the eight matters in subsection 177D(2) of the ITAA 1936, the Commissioner does not consider that any party to the Scheme entered into the Scheme for the sole or dominant purpose of obtaining a tax benefit. Accordingly, the Commissioner will not make a determination pursuant to section 177F of the ITAA 1936 to cancel the whole or part of any tax benefit that might be obtained in connection with the Scheme.