Private ruling: Sovereign Immunity
Date of advice: 6 November 2015
Published: January 2016

Ruling: Q1: Will Entity A and Entity B be immune from income and withholding taxes on distributions received from Entity B's interests in Entities C, D and E and any gains made by Entity B on the disposal of these interests under the common law doctrine of sovereign immunity? | A1: Yes.




Date of advice: 6 November 2015: In order to protect the privacy and commercial in-confidence components of the private binding ruling the following Question and Answer is provided.