Private ruling: Sovereign immunity
Date of advice: 21 December 2015
Published: February 2016
Ruling period: Years ended 30 June XXXX to XXXX
Date scheme commenced: During the year ended 30 June XXXX.

Ruling: Q1: Will the foreign government entity be exempt from income and withholding taxes on: • interest • income and gains from its investments • gains on the disposal of its investments under the common law doctrine of sovereign immunity? | A1: Yes.

Relevant facts and circumstances: The foreign government entity invests government funds.

Relevant legislative provisions: Income Tax Assessment Act 1936 section 128B | Income Tax Assessment Act 1997 section 4-1

Reasons for decision: Summary: The foreign government entity satisfies the conditions for exemption from income and withholding taxes under the doctrine of sovereign immunity in respect of interest, income and gains from its investments.