Private ruling: Subdivision 124-M Rollover
Published: September 2014
Ruling period: year ended 30 June 20xx
Date scheme commenced: during the year ended 30 June 20xx

Ruling: Q1: Will Shareholder 1 be regarded as a significant stakeholder or common stakeholder pursuant to section 124-783 of the Income Tax Assessment Act 1997 (ITAA 1997)? | A1: Yes | Q2: If the answer to question 1 is yes, is the arrangement described in question 1 a restructure for the purpose of section 124-784A of the ITAA 1997? | A2: Yes | Q3: Will any of the following Shareholders (x8) be regarded as a significant stakeholder or common stakeholders pursuant to section 124-783 of the ITAA 1997? | A3: No | Q4: If the answer to question 3 is yes, is the arrangement a restructure for the purpose of section 124-784A of the ITAA 1997? | A4: No | Q5: Will the first element of the cost base and reduced cost base of Replacement Entity in the Original Entity shares it acquires from Shareholder 1 be determined pursuant to subsection 124-782(1) of the ITAA 1997? | A5: Yes | Q6: Will the first element of the cost base and reduced cost base of Replacement Entity in the Original Entity shares it acquires from the Shareholders (x8) be determined pursuant to Divisions 110 and 112 of the ITAA 1997? | A6: Yes

Relevant facts and circumstances: The taxpayer, the Replacement Entity, applied for a private ruling in connection with a corporate group restructure under which the Replacement Entity is interposed between the Original Entity and its shareholders.

Relevant legislative provisions: Income Tax Assessment Act 1997 Subdivision 124-M | Division 110 | Division 112